The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) will enter into force on 1 December 2019. With the help of the BEPS Convention, existing double taxation agreements that are covered by it can be adapted to the tax treaty related recommendations from the OECD/G20 BEPS project.
Initially, the BEPS Convention should adapt the Swiss double taxation agreements (DTAs) with Argentina, Austria, Chile, the Czech Republic, Iceland, Italy, Lithuania, Luxembourg, Mexico, Portugal, South Africa and Turkey to the minimum agreement standards defined within the framework of the BEPS project. These countries are prepared to agree with Switzerland on the precise wording of the DTAs to be adapted via the BEPS Convention by means of mutual procedure agreements. Once the BEPS Convention has also entered into force in these countries and the individual agreements have been concluded, Switzerland will notify the conclusion of the national procedures in order for the provisions of the BEPS Convention to take effect.
The tax treaty related BEPS minimum standards can be agreed by means of the BEPS Convention or, alternatively, via bilateral DTA amendments. Switzerland has already incorporated these minimum standards into numerous revisions and newly signed DTAs. Further DTA revisions are under way.
Address for enquiries:
Tax Division, State Secretariat for International Finance SIF
Phone +41 58 462 60 45, email@example.com