UK and International Tax news
UK-Switzerland DTA Update
Tuesday 7th December 2010
The Double Taxation Relief and International Tax Enforcement (Switzerland) Order 2010 [SI 2689-2010] has recently been published. The Order specifically introduces two protocols which replace Articles 24 and 25 of the Convention with updated mutual agreement procedure and exchange of information articles which are in line with the new international standards for mutual agreement and exchange of information as set out in the Model Tax Convention on Income and on Capital published by the OECD.
The Exchange of Notes of 26 June 2007 which previously formed an integral part of the Convention as to the interpretation and understanding of certain terms are also replaced [see our Tax News item of 5 July 2007].
The Protocols will enter into force on the date of the later of the notifications by each country of the completion of its legislative procedures. They shall have effect with respect to paragraph 5 of Article 24 of the Convention, three years after the date of entry into force; and for all other matters, for taxable years beginning on or after 1st January of the year next following the date of entry into force. The date of entry into force will, in due course, be published in the London, Edinburgh and Belfast Gazettes.
If you would like further information on the protocols, please contact Keith Rushen on +44 (0)20 7486 2378Contact Us