01
Effective status
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.
This editorial overview does not replace the official treaty and protocol, domestic law or a factual analysis of the income recipient.
02
Dividends
General limit 15%; 5% for a company directly holding at least 10% of the payer's capital.
03
Interest
Treaty limit 0%.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
Residence, beneficial ownership, payment classification, anti-abuse limits and the Swiss relief or refund procedure must be tested. The 2004 transport agreement cannot be extended mechanically to other income. 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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