Switzerland and Armenia sign protocol of amendment to double taxation agreement

On 12 November 2021 in Yerevan, Switzerland and Armenia signed a protocol amending the agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. The protocol implements the BEPS minimum standards for double taxation agreements.

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.

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 18.11.2021

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