Amendments to the double taxation agreement with Japan to enter into force

Bern, 28.12.2011 - The revised double taxation agreement (DTA) with Japan signed on 21 May 2010 will enter into force on 30 December 2011. Switzerland and Japan have concluded the diplomatic exchange of notes on ratification. The agreement contains an OECD administrative assistance clause. The DTA will contribute to the further positive development of bilateral economic relations.

Compared with the current DTA, improvements have been achieved in the area of withholding taxes: payments of dividends between companies linked by holdings of at least 50% of the voting rights will benefit from the zero rate in future. If the stake is more than 10% of the voting rights, there will remain a residual tax of 5%. In future, a general zero rate will be applicable to royalty payments. Finally, interest payments to financial institutions (banks, insurance or reinsurance companies and securities dealers) or pension funds will also be exempt from withholding tax in future.

On 30 November 2011, Switzerland and Japan concluded the diplomatic exchange of notes on ratification of the DTA so that the agreement will, in accordance with the contractual text, enter into force 30 days later, i.e. on 30 December 2011. The provisions of the agreement will apply from 1 January 2012.

Address for enquiries

Urs Duttweiler
State Secretariat for International Financial Matters SIF
+41 31 322 72 52


Federal Department of Finance