In particular, the termination agreement governs the transfer of the last tax amounts and the transmission of the latest voluntary declarations to the UK tax authorities. The provisions of the withholding agreement continue to apply to all legal facts and rights that occurred during its validity. It is by no means certain that the two tax treaties will also overcome the obstacles of the Swiss parliament. Switzerland has also entered into a withholding agreement with Austria, which is terminated with the switch to the automatic standard for information exchange with the EU. The two countries signed an agreement to this effect on 11 November 2016. “I think that the German government has the means to avoid the failure of the project and thus avoid the humiliation of signing an agreement with a third country and getting put on the fingers of Brussels. The agreement with Germany could not be brought into force because of domestic political pressure. Nevertheless, the agreement could be re-discussed if the agreements with the United Kingdom and Austria work well. It was therefore necessary to keep in mind the main points of this agreement in case it becomes relevant again. Chapter 9 shows how Switzerland has attempted to propose an alternative model to the automatic exchange system in the form of the so-called “Rubik” agreements. These agreements were adopted between 2012 and 2017 with Austria and the United Kingdom. They argued for a system of final withholding tax on the income of Swiss payers, which is roughly in line with the current rate of the taxable person`s state of residence.

Since January 2017, these agreements have been repealed and replaced by a comprehensive bilateral agreement between Switzerland and the EU setting the OECD standard for automatic exchange of information. On 17 April 2012, the European Commission agreed to the tax agreements set up by Switzerland with Germany and the United Kingdom. The tax agreement between Switzerland and Austria was also approved. This agreement was signed on April 13, 2012. With these three agreements, the countries concerned want to better prevent tax evasion.