Switzerland and Belgium sign protocol of amendment to double taxation agreement
On 16 July 2025 in Brussels, Switzerland and Belgium signed a protocol of amendment to the agreement between Switzerland and Belgium for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the 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 also adapts the CDI to the current treaty policy of both countries on minor points
The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by parliament in both countries before it can come into force.
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