The protocol to the 1980 income tax treaty between New Zealand and Switzerland entered into force on 10 December 2020. The protocol, signed 8 August 2019, is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with BEPS standards;
- A new paragraph 7 is added to Article 7 (Business Profits), which provides that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of …