The protocol of amendment to the double taxation agreement (DTA) between Switzerland and Armenia has entered into force. Most of the provisions will apply from 1 January 2024, although some are applicable from the date of entry into force.
Following completion of the ratification processes in Switzerland and Armenia, the protocol of 12 November 2021 amending the agreement between the Swiss Confederation and Armenia for the avoidance of double taxation with respect to taxes on income entered into force on 2 May 2023.
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 supplements the provision on the mutual agreement procedure to bring it into line with the minimum standard. In addition, the protocol provides for a series of further improvements to the existing DTA, in particular the reduction of residual tax rates on dividends. Finally, it contains an administrative assistance clause in accordance with the international standard for the exchange of information upon request.
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 01.06.2023