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Old 22.09.2017, 19:59
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Re: Zug Domiciled Vested Pension 2 account

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I do not see the payment as an income at the day of payout. The income was in the past. If country X did not tax that income in the past should be of no concern for country Y.

Let say I have a similar account in an other country I would just declare it as part of my wealth here in Switzerland. No at payout time it just get transferred from one account into an other. My total wealth did not change, it actually reduced because of the payout tax I had to pay in the other country. Thus, it is not income from the Swiss point of view.

Now the problem. Damn Swiss tax law disagrees with my point of view: Art. 22 Abs. 1 DBG https://www.admin.ch/opc/de/classifi...index.html#a22


One has indeed be careful what the tax law in the other country defines as income and if maybe a double tax agreement may address such situations.
Most countries tax income in the year it became available to the taxpayer to spend themselves. I don't know any that tax as your suggested, it would appear not even Switzerland.

If the money is not taxable in the new country the Swiss withholding tax is final, if it is taxable elsewhere the entire Swiss tax can be reclaimed if a tax agreement exists & then the full tax is paid in the new country. Being Taxable in the new country is the key word as no tax actually needs to be paid.
I am in a interesting situation with my UK pension, I can elect that 11,500 is taxable in the UK & 13,500 euros worth taxable in Malta. In both case zero tax is actually payable as each country allows me that amount tax free, the only stipulation is I can't take the UK money to Malta or it would be taxable in Malta. I had to fill in the UK's DTA form with Malta & have Malta tax office stamp the form.
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