On 8 August 2019 in Wellington, Switzerland and New Zealand signed a protocol of amendment to the agreement 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. Moreover, an arbitration clause will be included in the DTA.
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. The agreement 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 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
Last modification 08.08.2019