Amendments to the double taxation agreement with Finland in force

Bern, 20.12.2010 - The protocol to amend the double taxation agreement (DTA) between Switzerland and Finland has entered into force. Aside from a provision on the exchange of information in accordance with the OECD standard, the protocol contains a reduction in the stake required for exemption from withholding tax on dividends and thereby contributes to promoting bilateral economic relations. All of the provisions of the protocol are now part of the revised DTA with Finland.

About one month ago, Switzerland and Finland informed one another via diplomatic channels that all of the conditions and legal procedures for the protocol's entry into force had been met. The revised DTA thereby came into force on 19 December 2010 in accordance with its provisions on entry into force. The provisions of the DTA will apply to dividends payable on or after 1 January 2011. In the case of administrative assistance in tax matters, the revised DTA will be applicable to tax years beginning on or after 1 January 2011.

The revised DTA now guarantees withholding tax exemption on dividends in the case of a stake of at least 10%. In the earlier DTA, withholding tax exemption was provided for only for stakes of at least 20%. The protocol to amend the DTA with Finland was signed in Helsinki on 22 September 2009, and was approved by parliament on 18 June 2010. The referendum deadline expired unused on 7 October 2010.

Address for enquiries

Pascal Duss, Division for International Affairs, Federal Tax Administration, tel. 031 322 71 57


Federal Department of Finance