Entry into force of the amending protocol to DTA with the United Arab Emirates
The amending protocol to the double taxation agreement (DTA) between Switzerland and the United Arab Emirateshas entered into force. With a few exceptions, most of the changes will apply from 1 January 2026.
Following the completion of the ratification procedures in Switzerland and the United Arab Emirates, the protocol of 5 November 2022 amending the agreement between the Swiss Confederation and the United Arab Emiratesfor the avoidance of double taxation with respect to taxes on income and on capital entered into force on 5 May 2025.
The protocol implements the minimum standards for double taxation agreements. In particular, it 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 also contains new provisions concerning the mutual agreement procedure.
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