U.S. tax treaty and FATCA position for Switzerland

Switzerland in the U.S. treaty list

The IRS A to Z list includes Switzerland among the countries with a U.S. income tax treaty. The IRS explains that treaty terms can reduce or exempt tax on certain income items. For residents or citizens of the United States, those terms may apply to certain income from sources in foreign countries, with rates and exemptions varying by country and income item.^[4]

The IRS also states that income outside a treaty's coverage is taxed under the instructions and rates for the applicable U.S. return. Some U.S. states do not honor tax treaty provisions.^[4]

Switzerland in Treasury's FATCA table

Treasury lists Switzerland with Model 2 in force and Model 1 signed.

Treasury explains that FATCA requires foreign financial institutions to report information to the IRS about accounts held by U.S. taxpayers or certain foreign entities. It says institutions may register directly with the IRS or comply with FATCA intergovernmental agreements treated as in effect in their jurisdictions.^[3]

What treaties and IGAs describe

The IRS describes tax treaties through their treatment of certain income items. The stated effects can include reduced tax rates or exemptions, and vary across countries and income types. For a U.S. citizen, the IRS says treaty provisions can concern foreign taxes on certain income sourced in foreign countries.^[4]

Treasury identifies the Model Intergovernmental Agreement as an agreement published to improve tax compliance and implement FATCA. In its description, FATCA reporting concerns financial account information sent by foreign financial institutions to the IRS.

A tax treaty addresses the tax treatment of specified income items, while a FATCA agreement addresses reporting by foreign financial institutions.

Table 3 of the IRS tax treaty tables lists general effective dates for U.S. income tax treaties.

Questions and answers

Related resources

Related glossary terms

• Treaty rate table: A treaty rate table summarizes income categories and tax rates or exemptions under U.S. income tax treaties. The IRS explains the tables' scope and limits.
• Foreign grantor trust: A foreign grantor trust is a foreign trust treated as owned by a grantor, often a U.S. person. Ownership brings Form 3520 and Form 3520-A reporting duties.
• Intergovernmental agreement: An intergovernmental agreement appears in FATCA rules for foreign financial institutions. Form 8938 instructions also use the term for certain foreign accounts.

Related articles and guides

• Belize and U.S. tax treaty and FATCA lists: Belize appears on neither the IRS treaty list nor the Treasury FATCA table. A treaty and a FATCA agreement are different instruments for U.S. citizens.
• Guernsey and U.S. tax agreements: Guernsey's entries in the IRS treaty list and the Treasury FATCA table, including its Model 1 status, and what both mean for U.S. citizen readers today.
• Bahamas tax treaty and FATCA agreement position: The IRS treaty list does not include the Bahamas, while Treasury lists a FATCA agreement entry for the jurisdiction. These tables cover distinct arrangements.

Tools and official documents

• FATCA agreement lookup: Look up any jurisdiction in the U.S. Treasury FATCA table and see its agreement model and status as the Treasury lists them, with a link to the source.

Related pages

• Switzerland: overview: Start page for this jurisdiction.
• Trust legislation
• Trustee regulation and licensing
• Taxation of trusts
• Reporting and information exchange