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Switzerland · DTA · DBA

Switzerland double-tax agreement navigator

Ten priority treaties for international families, holdings, foundations and companies, strictly separating effective rules from signed but not yet effective changes.

DTA · beneficial owner · PPT · MAP

Applying the treaty

A treaty rate is a maximum source-state limit, not an automatic rate. Before payment, test residence, beneficial ownership, minimum holding and holding period, PPT, substance, domestic law and the relief-at-source, notification or refund procedure.

01

Liechtenstein

SR 0.672.951.43 · Applies from 1 January 2017. The protocol of 14 July 2020 entered into force on 1 December 2021 and largely applies from 2022, adding BEPS/PPT and an updated MAP.

  • Dividends: General limit 15%; 0% for a company holding at least 10% where the holding-period condition is met, and for specified government, central-bank and pension bodies.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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02

United Arab Emirates

SR 0.672.932.51 · The protocol of 5 November 2022 entered into force on 5 May 2025; its principal changes apply from 1 January 2026 and include BEPS/PPT, an updated MAP and corresponding adjustment.

  • Dividends: General limit 15%; 5% for a company holding at least 10%; 0% for specified government and pension bodies.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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03

Austria

SR 0.672.916.31 · The effective treaty has been amended by protocols in 1994, 2000, 2006, 2009 and 2012. A new protocol was signed on 30 July 2026 but, as reviewed, is not yet in force and requires parliamentary approval in both states.

  • Dividends: Under the rules currently in force: general limit 15%; 0% for a direct corporate holding of at least 20%. The future 10% threshold in the new protocol does not yet apply.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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04

Germany

SR 0.672.913.62 · The latest protocol of 21 August 2023 entered into force on 27 November 2025; most changes apply from 1 January 2026, including BEPS/PPT, cross-border employment and MAP updates.

  • Dividends: General limit 15%; 0% for a direct corporate holding of at least 10% held for at least 12 months. Other special cases require review of the consolidated text.
  • Interest: Generally a 0% treaty limit; particular instruments and real-estate structures require separate review.
  • Royalties: Treaty limit 0%.
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05

Cyprus

SR 0.672.925.81 · The protocol of 20 July 2020 entered into force on 3 November 2021 and largely applies from 1 January 2022, adding BEPS/PPT and an enhanced MAP.

  • Dividends: General limit 15%; 0% for a company holding at least 10% for at least 12 months; 0% for specified government and pension bodies.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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06

Bahrain

SR 0.672.916.61 · The agreement entered into force on 27 July 2021 and appears in the official rate-limit table as at 1 January 2026. A separate 2004 agreement addresses income from international air and sea transport.

  • Dividends: General limit 15%; 5% for a company directly holding at least 10% of the payer's capital.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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07

Oman

SR 0.672.961.61 · The agreement entered into force on 13 October 2016 and has applied since 1 January 2017. While it applies, the separate 2007 agreement on international air-transport income is suspended.

  • Dividends: General limit 15%; 5% for a company holding at least 10%.
  • Interest: Treaty limit 5%.
  • Royalties: Treaty limit 8%.
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08

Hong Kong

SR 0.672.941.61 · The agreement entered into force on 15 October 2012; it applies to Swiss taxes from 1 January 2013 and Hong Kong taxes from 1 April 2013. The Switzerland–China DTA does not extend to Hong Kong.

  • Dividends: General limit 10%; 0% for a company holding at least 10%. Hong Kong domestic law generally imposes no withholding tax on dividends.
  • Interest: Treaty limit 0%; Hong Kong domestic law also generally imposes no withholding tax on interest.
  • Royalties: Treaty limit 3%.
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09

Singapore

SR 0.672.968.91 · The agreement entered into force on 1 August 2012. The official effect summary separately identifies relief for bank-to-bank interest, the central bank and transitional approved loans or licences.

  • Dividends: General limit 15%; 5% for a company holding at least 10%. Singapore generally imposes no domestic withholding tax on dividends.
  • Interest: General treaty limit 5%; 0% applies to specified bank-to-bank payments and identified public recipients.
  • Royalties: General treaty limit 5%.
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10

Netherlands

SR 0.672.963.61 · The 2010 agreement entered into force on 9 November 2011. The protocol of 12 June 2019 entered into force on 30 November 2020 and forms part of the current regime; a separate inheritance-tax treaty also remains in place.

  • Dividends: General limit 15%; 0% for a company holding at least 10%, subject to the treaty's anti-abuse conditions.
  • Interest: Treaty limit 0%.
  • Royalties: Treaty limit 0%.
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FTA · SIF

Official text and status

This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.

01

FTA DTA rate limits as at 1 January 2026

Federal Tax Administration

PDF ↗
02

SIF Swiss DTA overview

State Secretariat for International Finance

SIF ↗

This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.

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