The pending protocol to the 1999 income and capital tax treaty between Croatia and Switzerland was signed on 18 July 2025. It is the first to amend the treaty and includes the following changes:
- The title and preamble are replaced in line with OECD BEPS standards;
- Article 7 (Business Profits) is amended with the addition of a new paragraph 7 providing that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of…