Julian Kläser
Tax aspects of pension assets of internationally mobile employees
Employees are more mobile than ever. As a result, they often have occupational and private pension assets in several countries. The tax situation becomes confusing at the latest when a cross-border transfer or payment of these pension assets to the beneficiaries is to take place. This article first introduces the basics and presents the respective tax consequences in Switzerland with regard to the payout from the foreign pension forms on the basis of two cross-border practical examples.
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Switzerland's pension system is based on the 3-pillar principle. Tax law is based on this 3-pillar principle. The basic principle is that full deductibility of contributions is offset by full taxation of benefits. This model applies to the 1st and 2nd pillars as well as to tied private pension plans. The free personal pension plan enjoys only limited tax privileges on the contribution side, and accordingly only partial or, at best, no taxation of the benefits paid out takes place. In principle, the taxation rules for foreign pension benefits are applied in the same way, provided that there is comparability. However, it is always advisable to consider each individual case, as the practical examples in this article make clear. On the one hand, the tax treatment of the transfer of the accumulated capital from an American IRA pension plan and, on the other hand, the payment of a German Rürup pension are presented from a Swiss perspective. It becomes clear that persons concerned with pension assets in different countries should analyse their individual tax situation beforehand.
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