Analysing the Sino-Swiss double taxation agreement

By Christoph Niederer and Wu Fan, Vischer

According to our observations, Chinese entrepreneurs have become more aware of tax issues when considering offshore investments. One of their first questions in this regard is often whether income received from their Swiss affiliates would be taxed both in Switzerland and in China, or whether comparable taxes would be imposed for the same item by both the Swiss and Chinese tax authorities.

Double taxation is harmful to the international exchange of goods and services, and cross-border movements of capital, technology and persons. In recognition of the need to remove this obstacle, the Swiss government has concluded double taxation agreements (DTAs) with more than 90 countries; the Sino-Swiss DTA has been in effect since 1991.

Christoph Niederer 菲谢尔律师事务所 合伙人、税务团队主管 Partner and Head of the Tax Team VISCHER
Christoph Niederer
Partner and Head of the Tax Team

Business profits

According to the Sino-Swiss DTA, the profits of an enterprise of a contracting state will be taxed only in that contracting state, unless the enterprise carries on business in the other contracting state through a permanent establishment (PE) situated there.

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Christoph Niederer is partner and head of the tax team at the Swiss law firm Vischer, and Wu Fan is counsel at Vischer


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Christoph Niederer

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吴帆 Wu Fan

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