UK- Switzerland Tax agreement
A new protocol to the Double Taxation Convention between the UK and Switzerland was recently signed in London by the Financial Secretary to the Treasury and the Swiss Ambassador.
The protocol updates the exchange of information clauses to bring the Convention in line with the OECD’s model. Briefly, the Article is drafted to allow for the exchange of information up to OECD and international tax standards to prevent fraud and tax evasion.
The protocol also inserts an arbitration provision into the mutual agreement procedure article which can be relevant if there is disagreement between the two tax authorities on the allocation of taxing rights (relevant to transfer pricing).
The protocol will take force once both countries have finalised the necessary legislative procedures. The provisions will then take effect for tax years beginning on or after 1 January of the calendar year following its entry into force.