The Protocol of Amendment to the Double Taxation Agreement (DTA) between Switzerland and Japan has entered into force. With the exception of individual provisions, most of the amendments are applicable as of January 1, 2023.
Following the completion of the ratification procedures in Switzerland and Japan, the Protocol of 16 July 2021 amending the Agreement entered into force on 30 November 2022.
The protocol implements minimum standards for DTAs from the BEPS project. In addition, it provides for a number of innovations, including an arbitration clause and new rules for exemption from withholding tax on interest or dividends in the case of qualifying holdings.
The Protocol of Amendment to the DTA Japan or the media release can be downloaded here.