Switzerland Signs New DTA Protocols

by Ulrika Lomas, Tax-News.com, Brussels

10 September 2015

Switzerland has signed protocols to its double taxation agreements (DTAs) with Norway and Albania.

The protocol to Switzerland's DTA with Norway was signed in Oslo on September 4, 2015. It introduces an arbitration clause that is in line with the Model Tax Convention drawn up by the Organisation for Economic Cooperation and Development (OECD) and is in accordance with Switzerland's current policy on tax agreements.

In 2009, Switzerland and Norway agreed a most favored nation clause that would be triggered in the event that Norway agreed to an arbitration clause with another jurisdiction. The September 2015 protocol implements this clause. At Norway's request, the article on the exchange of information has also been updated.

The protocol to Switzerland's DTA with Albania was signed on September 9, 2015. It introduces an administrative assistance clause in line with the international standard for the exchange of information upon request. It also provides for the inclusion of an arbitration clause, to ensure that double taxation is avoided.

A future developments clause on the taxation of royalties will mean that Switzerland benefits if Albania enters into more favorable agreements with countries in the European Union or European Economic Area. An anti-abuse provision will preclude the DTA's use by persons who are not entitled to its benefits.

Both protocols must be approved by the countries' respective parliaments before they can enter into force.

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