Entry into force of the protocol of amendment to DTA with North Macedonia
The protocol of amendment to the double taxation agreement (DTA) between Switzerland and North Macedonia has entered into force. The changes will apply from 1 January 2027.
Following the completion of the ratification procedures in Switzerland and North Macedonia, the protocol of 19 May 2021 amending the agreement between the Swiss Confederation and the Repulic of Norch Macedonia for the avoidance of double taxation with respect to taxes on income and on capital entered into force on 22 October 2026.
The protocol implements OECD’s minimum standards for double taxation agreements. In particular, the protocol of amendment contains an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused. It contains also an administrative assistance clause in accordance with the international standard for the exchange of information upon request. The protocol also introduces an arbitration clause which will provide legal certainty.
Address for enquiries:
Bilateral Tax Issues and Double Taxation Treaties Section, State Secretariat for International Finance SIF
Tel. +41 58 462 71 29, dba@sif.admin.ch