Switzerland and Finland sign protocol of amendment to double taxation agreement
On 28 May 2026 in Helsinki, Switzerland and Finland signed a protocol amending the double taxation agreement (DTA) on income tax. This protocol implements the minimum standards for double taxation agreements.
This protocol implements the minimum standards of the BEPS project for DTAs. Specifically, the protocol of amendment contains an anti-abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused. It also supplements the provision on the mutual agreement procedure in accordance with the minimum standard and introduces the arbitration procedure.
The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by the legislator 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