Swiss Federal Council Approves Revised Japanese DTA

by Ulrika Lomas, Tax-News.com, Brussels

03 July 2009

Japan and Switzerland have agreed on a text for a revised double taxation agreement. Negotiations on revising the existing Swiss-Japanese double tax convention of 1971 have been ongoing since November 2008, and were prolonged following the Swiss Federal Council's March 13, 2009, decision, which lead to the two parties agreeing to also include a provision on administrative assistance in tax matters in accordance with Article 26 of the OECD Model Convention.

The Federal Council decided on March 13, 2009, that Switzerland would change policy on international cooperation in tax matters and adopt the OECD standard on administrative assistance in tax matters under Article 26 of the OECD Model Convention. The decision will permit an exchange of information on tax matters in individual cases where a specific and justified request has been made.

In addition Switzerland and Japan agreed to make dividends on significant participations, certain types of interest in the finance sector and royalty payments exempt from withholding tax.

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