Switzerland, Norway and Albania sign protocol to amend double taxation agreement

09.09.2015 in Tirana, Switzerland and Albania signed a protocol amending the agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. This protocol introduces an administrative assistance clause in line with the international standard for the exchange of information upon request. The new DTA will contribute to the positive development of bilateral economic relations.

Aside from the new provision on the exchange of information for tax purposes, the agreement has been modified in other respects in line with Switzerland's current agreement policy, particularly with the introduction of an arbitration clause to ensure that double taxation is avoided. With regard to royalties, a future developments clause will enable Switzerland to benefit from any more favourable DTAs that Albania subsequently enters into with a country in the European Union (EU) or European Economic Area (EEA). Finally, an anti-abuse clause will preclude the use of the agreement by persons who are not entitled to the benefits it grants.

After negotiations finished, the protocol amending the agreement was initialled on 19 February 2015. It was then submitted to the cantons and the business associations concerned for consultation, and it did not encounter any opposition. It still has to be approved by parliament in both countries before it can enter into force.

Switzerland and Norway sign protocol to amend double taxation agreement

On 4 September 2015 in Oslo, Switzerland and Norway signed a protocol amending the agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. This protocol introduces an arbitration clause in line with the OECD Model Tax Convention and Switzerland's current agreement policy. The new DTA will contribute to the positive development of bilateral economic relations.

Switzerland and Norway amended their agreement in 2009 in order to add a provision on the exchange of information in line with the international standard. At that time, a most favoured nation clause was also agreed in Switzerland's favour in the event of Norway agreeing to an arbitration clause with another partner. This protocol of amendment implements that most favoured nation clause and introduces an arbitration clause that ensures double taxation is avoided. At Norway's request, Article 26 on the exchange of information has also been updated.

After negotiations finished, the protocol amending the agreement was initialled on 13 March 2015. It was then submitted to the cantons and the business associations concerned for consultation, and it did not encounter any opposition. It still has to be approved by parliament in both countries before it can enter into force.

Switzerland has signed a total of 52 double taxation agreements in line with the international exchange of information standard, and 41 of these are in force.