01
Effective status
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.
This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.
02
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.
03
Interest
Treaty limit 0%.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
The effective regime and the signed but not yet effective protocol must be kept strictly separate. A separate inheritance-tax treaty, SR 0.672.916.32, also exists. 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.
06
Practical sequence
- Determine residence and the relevant tax period
- Classify the income and beneficial recipient
- Test the holding, holding period, PPT and business purpose
- Prepare certificates, forms and substance evidence
- Coordinate withholding, notification or refund and MAP where needed
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