The amending protocol to the 1966 income and capital tax treaty between Ireland and Switzerland entered into force on 21 October 2020. The protocol, signed 13 June 2020, is the third to amend the treaty and includes the following changes:
- The preamble is replaced in line with BEPS standards;
- Article 6 (Business Profits) is amended with the addition of the provisions that "A Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an ente…