On 19 July 2017 the supplementary agreement amending the double taxation agreement (DTA) in the area of taxes on income and assets between Switzerland and Belgium came into force.
The supplementary agreement amending the DTA with Belgium was signed by both states on 10 April 2014. It adapts the 1978 double taxation agreement with Belgium to the current situation. The supplementary agreement contains the current international standard for the exchange of information on request and entered into force on 19 July 2017. Its provisions shall apply from 1 January 2018.
Furthermore, the supplementary agreement brings improvements in the taxation of dividends, interest and royalties. In particular, tax exemptions in the source state could be agreed for pension funds. Further improved taxation arrangements have been negotiated for interest on inter-company loans and dividends to certain companies. Accordingly, the supplementary agreement now provides, among other things, for a zero rate for dividends from qualified participations. A qualifying holding shall be deemed to exist where the beneficial owner is a company which directly holds, for a continuous period of at least 12 months, at least 10% of the capital of the company paying the dividends. The newly agreed rules promote investment and economic exchange in bilateral relations.
The corresponding press release of the Federal Department of Finance (FDF) dated 7 August 2017 is available here.
