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| Switzerland, Canada DTA Amendments In Force |
by Ulrika Lomas, Tax-News.com, Brussels
Friday, December 23, 2011
Switzerland’s Federal Department of Finance (FDF) has announced that
the Protocol of Amendment of October 22, 2010, to the double taxation agreement
(DTA) between Switzerland and Canada has now entered into force.
According to the FDF, the protocol contains provisions on the exchange of
information in accordance with the international standard applicable at present,
and is designed to contribute to the further positive development of bilateral
economic relations.
In its release, the FDF notes that: “Aside from the exchange of information
in accordance with the internationally applicable standard, Switzerland and
Canada have agreed to exempt dividend payments to pension funds and the central
bank from withholding tax.”
It adds: “Interest payments between unrelated persons will also be exempt
from withholding tax in the future. Moreover, the scope of application of the
withholding tax exemption for royalty payments has been extended, and an arbitration
clause has been added.”
It concludes: “Finally, as a result of the Protocol of Amendment, Swiss
residents in receipt of Canadian social security will see the previous double
taxation of such benefits abolished.”
The provisions of the Protocol of Amendment, approved by parliament in both
countries, are due to apply from January 1, 2012.
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