On 16 July 2021, Switzerland and Japan signed an amendment protocol to the double taxation agreement that implements the minimum standards under BEPS.
It contains a PPT (Principal Purpose Test) clause, the provision on the mutual agreement procedure was added in accordance with the minimum standard and the arbitration procedure was introduced.
The protocol also standardises the tax relief in the source state for dividends from qualified participations (relief from a participation of the company of 10%) as well as for interest (the relief is linked to the condition that the interest is not defined as dependent on the income, sales or profits).
In both countries, the protocol still needs to be approved by the legislature to enter into force.
Further information is available here .
