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Switzerland Revives DTA With Argentina

by Ulrika Lomas,, Brussels

21 March 2014

Switzerland and Argentina have recently signed a new agreement for the avoidance of double taxation with respect to taxes on income and on capital.

The treaty replaces the provisional agreement of 1997 and provides for the exchange of information upon request, in line with the current international standard. This is until such time as the automatic exchange of information is established as the new international standard, requiring further bilateral discussions.

The new accord includes most of the solutions provided for in the previous agreement. It aims to eliminate the double taxation of dividends, interest payments, and royalties, and will foster good economic relations. The text will make it possible to fill the treaty vacuum between the Confederation and its Group of Twenty Nations partner. Argentina denounced the 1997 agreement on January 16, 2012.

The revised agreement has been approved by the Swiss cantons and business associations, and now requires parliamentary approval in both treaty states before entering into force. In the meantime, the exchange of notes of 1950 concerning the taxation of shipping and air transport companies will continue to apply.

To date, Switzerland has signed 43 double taxation agreements in line with the current international exchange of information standard, of which 36 are in force.

Switzerland also recently signed tax information exchange agreements (TIEAs) with Greenland and Andorra. Both agreements have to be approved by the Swiss parliament before they can enter into force and are subject to an optional referendum.

Switzerland has signed five TIEAs to date. Aside from the treaties with Greenland and Andorra, it has negotiated similar agreements with the Isle of Man, Jersey and Guernsey, and is actively pursuing the conclusion of new TIEAs with interested jurisdictions. Andorra confirmed that it has so far signed 22 TIEAs

TAGS: Isle of Man | tax | business | tax information exchange agreement (TIEA) | double tax agreement (DTA) | interest | royalties | Organisation for Economic Co-operation and Development (OECD) | Guernsey | Jersey | agreements | withholding tax | Switzerland | dividends | G20 | individual income tax | Andorra | Argentina | Greenland

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