Details of the protocol to the France-Switzerland tax treaty, signed on 12 January 2009, have become available. The protocol introduces important changes to, inter alia, the dividends (Arts. 11 and 14) and exchange of information (Art. 28 and additional protocol) articles of the treaty. The protocol is not yet in force.
Dividends
The protocol provides that the exemption of dividends from withholding tax does not apply to dividends paid to a company which…