Federal Council adopts dispatches on amendment of double taxation agreements with Ireland and Korea

During its meeting on 20 September 2019, the Federal Council adopted the protocols of amendment to the double taxation agreements (DTA) with Ireland and Korea. The protocols implement the minimum standards for double taxation agreements. In addition, an arbitration clause will be included in the DTA with Ireland. Both dispatches were submitted to Parliament.

The protocols of amendment contain an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTAs are not abused. The agreement with Ireland will also be supplemented by an arbitration clause, which will ensure greater legal certainty for taxpayers.

The cantons and the business circles concerned have welcomed the conclusion of the protocols of amendment. The protocols have to be approved by parliament in both countries before they 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