(September 10, 2015)

On September 9, 2015 the Swiss Federal Department of Finance issued a press release announcing that on September 4, 2015 Switzerland and Norway signed a protocol amending their existing DTA with respect to taxes on income and capital.

Although signed, the Protocol has not yet entered into force. For the Protocol to enter into force, the respective ratification procedures have to have been finalized in both countries.

Below we will discuss a selection of the regulations included in the recently signed Protocol of which we think they might interest our readers.

The protocol introduces an arbitration clause into Article 25 of the existing DTA.

The Protocol arranges that existing Article 26 (“Exchange of Information”) is deleted and replaced by a new Article 26 (“Exchange of Information”).  In this respect the Protocol also arranges that a new Paragraph 5 is added to the existing Protocol. This new Paragraph 5 arranges that for the interpretation of Article 26 the principles established in the OECD Commentaries shall be considered.

The Protocol also arranges that as of entering into force of the recently signed Protocol, the interpretation and application in relation to Article 26 of the Convention as specified by the Contracting States through the exchange of letters of August 31, 2009 and of May 15/June 13, 2012 shall no longer apply.

Click here to be forwarded to the full text of the Protocol between the Swiss Confederation and the Kingdom of Norway amending the Convention of 7 September 1987 between the Swiss Confederation and the Kingdom of Norway for the avoidance of double taxation with respect to taxes on income and on capital as available on the website of the Swiss Federal Department of Finance, which will open in a new window.

Are you looking for an other DTA? Then check our section DTAs & TIEAs, which is a very efficient way to locate numerous DTAs.

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