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Amendments to Switzerland's double taxation agreements (DTAs) with Norway and Albania have entered into force, the Swiss Federal Council has announced.
The protocol to the Norwegian DTA was signed in September 2015 and entered into force on December 6, 2016. Its provisions will be applicable from January 1, 2017.
The protocol introduces a most favored nation clause – extending any more preferential terms agreed with another territory bilaterally to this agreement – and inserts a new arbitration clause. It also amends the article on the exchange of information, at Norway's request.
The protocol to the Albanian DTA was also signed in September 2015, and entered into force on December 1, 2016. Its provisions will likewise be applicable from January 1, 2017.
The protocol provides for the inclusion of an arbitration clause that will ensure the avoidance of double taxation. An "evolutionary" clause on royalty payments means that any more advantageous agreements concluded by Albania with members of the European Union or the European Economic Area will also be applicable to cross-border dealings with Switzerland.
In addition, the Protocol updates the tax information exchange provisions and introduces an anti-abuse clause to prevent the agreement being used by people who are not entitled to its benefits.
To date, Switzerland has signed 54 DTAs and 10 tax information exchange agreements that are in line with the international standard on the exchange of information upon request. Of these, 50 DTAs and eight TIEAs are in force.
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