The protocols contain an anti-abuse clause.
The tax authority is considering whether to appeal the decision.
The BEPS MLI will enter into force in both countries on December 1, 2019.
Transfer pricing advisory Questro International has hired Chris Whitehouse as a transfer pricing partner for its Zurich office.
The treaty protocol provides for a low withholding tax rate of five percent for royalty and interest payments. An arbitration clause is also included to increase legal certainty for taxpayers.
Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.
Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.
The new anti-abuse measures entered into force on January 1, 2019.
An arbitration clause is included in the new tax treaty to resolve double taxation disputes.
The Swiss Federal Council on October 17 decided to expand the list of countries with which Switzerland would exchange country-by-country (CbC) reports.
The legal basis for the exchange of CbC reports entered into force for Switzerland on December 1, 2017. Switzerland had then submitted to the OECD a list of 108 countries with which the Government will exchange CbC reports.
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.
The protocol to amend the Switzerland-Latvia tax treaty entered into force on September 3, 2018, and will take effect from January 1, 2019.
The Swiss Federal Council on August 22 adopted the dispatch concerning a protocol of amendment to the Swiss-UK tax treaty for the attention of Parliament.
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (firstname.lastname@example.org) and by phone (+447808558597).
The Swiss Federal Council on Wednesday adopted the dispatch on the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.
The Swiss Federal Council on August 15 adopted the dispatch on the tax treaty with Saudi Arabia.