At its meeting on September 20, 2019, the Federal Council adopted the dispatches on the protocols of amendment to the double taxation agreements (DTAs) with Ireland and Korea. The protocols implement the minimum standards for DTAs. An arbitration clause will also be included in the DTA with Ireland. Both dispatches were referred to the Federal Assembly.
The protocols of amendment contain an abuse clause which is based on the main purpose of a design or transaction and thus ensures that the DTAs are not abused. The agreement with Ireland is also supplemented by an arbitration clause, which ensures greater legal certainty for taxpayers.
The cantons and interested business circles have responded positively to the conclusion of the protocols of amendment. Before the protocols can enter into force, they must be approved by the parliaments of both countries.
The media release and the relevant documents (minutes of amendments, messages on the minutes of amendments and the relevant federal decrees) are available here.
