Switzerland and Spain sign revised double taxation agreement

Berne, 27.07.2011 - Today in Madrid, Switzerland and Spain signed the protocol to amend the double taxation agreement (DTA) in the area of taxes on income and capital. The revision will contribute to the further positive development of bilateral economic relations. The revised DTA also contains provisions on the exchange of information in line with the internationally applicable standards.

Aside from the exchange of information, Switzerland and Spain have in particular agreed that in future no withholding tax will be levied on dividend payments from significant holdings of at least 10% (up to now 25%) in the capital of the company making the payment, as well as on dividend payments to pension funds. The holding period for capital stakes in the company making the payment will be reduced from the current period of two years to one year. In addition a comprehensive arbitration clause was included in the revised DTA.

After negotiations finished, a report on the revised agreement was submitted to the cantons and business associations concerned for their comments. They largely approved the signing of the agreement.

Address for enquiries

François Bastian, Division for International Affairs, Federal Tax Administration,
031 322 71 52, Francois.Bastian@estv.admin.ch


Federal Department of Finance

The Federal Council