Amendments to the double taxation agreement with Canada enter into force

Bern, 20.12.2011 - On 16 December 2011, the Protocol of Amendment of 22 October 2010 to the double taxation agreement (DTA) between Switzerland and Canada entered into force. It contains provisions on the exchange of information in accordance with the international standard applicable at present. The Protocol of Amendment will contribute to the further positive development of bilateral economic relations.

Aside from the exchange of information in accordance with the internationally applicable standard, Switzerland and Canada have agreed to exempt dividend payments to pension funds and the central bank from withholding tax. Interest payments between unrelated persons will also be exempt from withholding tax in the future. Moreover, the scope of application of the withholding tax exemption for royalty payments has been extended, and an arbitration clause has been added. Finally, as a result of the Protocol of Amendment, Swiss residents in receipt of Canadian social security will see the previous double taxation of such benefits abolished.

The provisions of the Protocol of Amendment will apply from 1 January 2012. The Protocol of Amendment has been approved by parliament in both countries.

Address for enquiries

Eric Hess
Tax Division
State Secretariat for International Financial Matters, SIF
+41 31 322 76 70


Federal Department of Finance