Switzerland, Canada DTA Amendments In Force

by Ulrika Lomas, Tax-News.com, Brussels

23 December 2011

Switzerland’s Federal Department of Finance (FDF) has announced that the Protocol of Amendment of October 22, 2010, to the double taxation agreement (DTA) between Switzerland and Canada has now entered into force.

According to the FDF, the protocol contains provisions on the exchange of information in accordance with the international standard applicable at present, and is designed to contribute to the further positive development of bilateral economic relations.

In its release, the FDF notes that: “Aside from the exchange of information in accordance with the internationally applicable standard, Switzerland and Canada have agreed to exempt dividend payments to pension funds and the central bank from withholding tax.”

It adds: “Interest payments between unrelated persons will also be exempt from withholding tax in the future. Moreover, the scope of application of the withholding tax exemption for royalty payments has been extended, and an arbitration clause has been added.”

It concludes: “Finally, as a result of the Protocol of Amendment, Swiss residents in receipt of Canadian social security will see the previous double taxation of such benefits abolished.”

The provisions of the Protocol of Amendment, approved by parliament in both countries, are due to apply from January 1, 2012.

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