Switzerland, Denmark Initial OECD Model Tax Treaty

by Ulrika Lomas, Tax-News.com, Brussels

28 May 2009

Switzerland and Denmark have signed a revised double taxation agreement, to provide for administrative assistance in tax matters under Article 26 of the OECD Model Convention. The agreement was negotiated in accordance with the key points agreed by the Federal Council.

According to a statement from the Swiss Federal Council, the initialled double taxation agreement (DTA) with Denmark will now be submitted to the cantons and business associations concerned for their comments. The first double taxation agreement with the new administrative assistance provisions is likely to be subject to an optional referendum, with the decision on whether the referendum will go ahead resting with parliament. After the DTA has been approved, the Federal Assembly must then ratify the treaty before it can come into force.

The Federal Council’s latest announcement follows on from its March 13, 2009, commitment 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.

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