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Swiss Federal Council Approves Pending Protocols to Tax Treaties with New Zealand, Netherlands, Norway, and Sweden

The Swiss Federal Council has announced its adoption on 6 November 2019 of the dispatches for the approval of the pending protocols to the 1980 tax treaty with New Zealand (previous coverage), the 2010 tax treaty with the Netherlands (previous coverage), the 1987 tax treaty with Norway (previous coverage), and the 1965 tax treaty with Sweden (previous coverage).

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Federal Council adopts dispatches on amendment of double taxation agreements with New Zealand, Netherlands, Norway and Sweden

Bern, 06.11.2019 - During its meeting on 6 November 2019, the Federal Council adopted the protocols of amendment to the double taxation agreements (DTA) with New Zealand, the Netherlands, Norway and Sweden. The protocols implement the minimum standards for double taxation agreements.

The protocols of amendment contain an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTAs are not abused. The agreement with New Zealand has also been supplemented by an arbitration clause, which ensures greater legal certainty for taxpayers. The protocol with the Netherlands additionally clarifies the concept of a pension scheme and creates a non-exclusive right for the source state to tax pensions.

The cantons and the business circles concerned have welcomed the conclusion of the protocols of amendment. The protocols have to be approved by parliament in the relevant countries before they can come into force.

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