Double Taxation Convention- Switzerland
A new protocol which came into force on 22 December 2008 makes some changes to the existing double taxation agreement between the UK and Switzerland.
The main changes relate to the elimination of taxation at source for certain dividends as well as additional measures in relation to pensions. The pension changes mean that, going forward, lump sum payments will only be taxed in the country in which they arise and in certain cases pension contributions paid in one country will be deductible in the other.
The protocol also addresses the exchange of information to help combat tax fraud and includes the exchange of information involving holding companies.
The new protocol is effective in Switzerland with effect from 1 January 2009 and in the UK from 1 April 2009 for corporation tax and from 6 April 2009 for income tax and capital gains.