Switzerland and the United Arab Emirates signed a protocol amending the agreement for the avoidance of double taxation (DTA) in the area of taxes on income in Abu Dhabi on November 5, 2022. The protocol implements the minimum standards from the BEPS project in matters of double taxation agreements.
The amending protocol contains an abuse clause that focuses on the main purpose of a design or transaction and thus ensures that the DTA is not abused. In addition, it supplements the provision on the mutual agreement procedure in accordance with the minimum standard.
Before the protocol can enter into force, it must be approved by the legislature in both countries.
The change log is available here.
