Switzerland and Kosovo signed a double taxation agreement (DTA) in the area of taxes on income and wealth on 26 May 2017.
According to a media release dated 26 May 2017, the DTA between Switzerland and Kosovo contains an abuse clause which corresponds to the recommendations of the OECD and G20 Base Erosion and Profit Shifting (BEPS) project, as well as an arbitration clause and an administrative assistance clause in accordance with current international standards on the exchange of information on request.
- Dividends are generally taxed at source at a maximum of 15% and dividends from qualifying holdings at a maximum of 5%. A qualified interest exists if the beneficial owner is a company (but not a partnership) that directly holds at least 25% of the capital of the company paying the dividends for a period of 365 days. For the purpose of calculating this period, changes in ownership resulting directly from a merger, division or transformation of the companies involved are not taken into account.
- Interest is taxed at a maximum of 5% at source.
- Royalties are taxed only in the State of residence of the beneficial owner.
The signed agreement is available here and must be approved by the parliaments of both countries before it can enter into force.
