The United States and Switzerland have entered into a double taxation agreement to avoid the double taxation of income and capital gains that may occur when individuals and companies are subject to taxation in both countries.

The agreement, which was signed on October 2, 1996, provides a set of rules to determine which country has the right to tax specific types of income, such as dividends, interest, and royalty payments. It also contains provisions for the exchange of information between tax authorities of both countries to promote compliance with their respective tax laws.

Under the agreement, residents of one country are taxed on their worldwide income in their country of residence, while income from the other country is taxed only in that other country. In some cases, such as with dividends and interest, the tax rate in the country of residence may be limited to a certain percentage of the income.

For example, if a Swiss resident earns dividend income from a US corporation, the US will withhold a portion of the dividend as tax, but the Swiss resident can claim a credit for the amount withheld against their Swiss tax liability. This prevents the same income from being taxed twice in both countries.

The double taxation agreement also covers the taxation of capital gains, such as the sale of shares or real estate. In most cases, the country where the property is located will have the right to tax the capital gain. However, there are some exceptions, such as for gains from the disposal of shares in a company, which are taxed only in the country where the shareholder is a tax resident.

The agreement also contains provisions for the resolution of disputes between the tax authorities of the two countries. If a taxpayer believes that they are being taxed unfairly or that their rights are being violated under the agreement, they can request assistance from the tax authorities of their country of residence, who will work with the other country to resolve the issue.

Overall, the double taxation agreement between the United States and Switzerland provides a framework for the fair and efficient taxation of income and capital gains earned by residents of both countries. It ensures that taxpayers are not subjected to double taxation and promotes compliance with tax laws through the exchange of information between tax authorities.