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Switzerland, Slovakia Initial Revised DTA

Friday, March 12, 2010

It has recently emerged that Switzerland and Slovakia have initialled a revised bilateral double taxation agreement, containing the Organization for Economic Cooperation and Development’s (OECD) standard on tax information exchange.

Following the successful conclusion of recent negotiations, Switzerland and Slovakia have initialled a Protocol of Amendment on the existing double taxation agreement (DTA) in place between the two countries. According to Switzerland’s Federal Administration, the administrative assistance clause is in line with the key points agreed by the Federal Council. Switzerland’s agreement with Slovakia is the 20th containing an administrative assistance clause, the Federal Administration notes.

Since the Swiss Federal Council’s decision on March 13, 2009, to extend administrative assistance in tax matters, Switzerland has initiated corresponding negotiations with numerous states. Since then, the Federal Council has also approved the first ten dispatches on revised DTAs conforming to Article 26 of the OECD’s Model Convention, and has subsequently submitted them to parliament for approval.

According to a statement from the Swiss Federal Administration: “Along with extending administrative assistance in tax matters, Switzerland has also been able to negotiate various benefits for the economy in the negotiations with these countries, such as reductions in withholding tax on dividends, interest and royalty payments, as well as the introduction of an arbitration clause. The avoidance of tax discrimination has also been achieved. This policy will be pursued and further negotiations are already envisaged with important countries.”