The Swiss Federal Department of Finance has announced the signing on 13 June 2019 of an amending protocol to the 1966 tax treaty with Ireland. The protocol 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 enterprise of one of the Contracting States after 5 ye…