01
Effective status
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.
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 company holding at least 10% where the holding-period condition is met, and for specified government, central-bank and pension bodies.
03
Interest
Treaty limit 0%.
04
Royalties
Treaty limit 0%.
05
Applying the treaty
Beneficial ownership, the one-year holding test for the corporate exemption, PPT, residence and the Swiss refund or notification procedure are central. 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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