At its meeting on 6 November 2019, the Federal Council adopted the messages concerning the Protocols of Amendment to the Double Taxation Agreements (DTAs) with New Zealand, the Netherlands, Norway and Sweden.
According to the media release of the Federal Department of Finance (FDF) of 6 November 2019, the Protocols implement the minimum standards regarding double taxation agreements.
All change logs contain an abuse clause that addresses the primary purpose of a design or transaction.
- An arbitration clause has also been added to the agreement with New Zealand.
- The Protocol with the Netherlands also clarifies the concept of a pension institution and creates a non-exclusive right for the source State to tax pensions.
The media release of the Federal Council as well as the corresponding documents (messages, decisions of the Federal Council and the minutes of amendments) can be downloaded here.
