01
Effective status
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.
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%; 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.
03
Interest
Generally a 0% treaty limit; particular instruments and real-estate structures require separate review.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
The 12-month holding test, PPT, cross-border worker rules, PE allocation and the separate inheritance-tax treaty SR 0.672.913.61 are particularly important. 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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