Executive summary
The Swiss competent authorities have released a statement clarifying that, on the basis of the Most Favored Nation (MFN) clause in the India-Switzerland tax treaty (the Treaty), Lithuania's and Colombia’s accession to the Organisation for Economic Co-operation and Development (OECD) has the effect of retroactively1 reducing the residual tax rate in the source State for dividends from 10% to 5% for qualified participations under the Treaty.
This Alert summarizes the statement…