On 5 November 2022 in Abu Dhabi, Switzerland and the United Arab Emirates signed a protocol amending the agreement for the avoidance of double taxation (DTA) with respect to taxes on income. The protocol implements the BEPS minimum standards for double taxation agreements.
The Protocol of Amendment was signed by the head of the Federal Department of Foreign Affairs (FDFA), President of the Swiss Confederation Ignazio Cassis, and the Foreign Minister of the United Arab Emirates, Abdullah bin Zayid Al Nahyan. It 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 protocol of amendment also supplements the provision on the mutual agreement procedure to bring it into line with the minimum standard.
The cantons and interested business sectors 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.
Further details:
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 05.11.2022