Amending Protocol to the DTT between Sweden and Switzerland
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On 28 February 2011, Sweden and Switzerland signed an amending protocol to the Income and Capital Tax Treaty of 7 May 1965 as amended by the protocol of 10 March 1972.
The new protocol came into force on 5 August 2012 and will apply as of 1 January 2013.
The default tax rates provided by the protocol will remain as follows:
| Dividends: | 15% |
| Interest: | 0% |
Swiss pension funds
The protocol provides for a tax rate of 0% on dividends paid to Swiss pension funds, on condition that:
- Such dividends are not derived from the carrying on of a trade or business by the pension fund, directly or through an associated enterprise; and
- The shares from which the dividends are derived are not sold, or agreed to be sold, by the Swiss pension fund within two months from the purchase of the shares.
Note: Relief at source is not available for withholding tax on dividend payments to Swiss pension funds and reclaim is only available directly through the Swedish Tax Authorities.
Swiss investment funds
The new amending protocol contains an article on exchange of information between Sweden and Switzerland, the inclusion of which enables Swiss investment funds to be exempt from withholding tax on dividends.
The documentation and procedures for relief at source and/or standard refund of withholding tax on dividends paid to Swiss investment funds are currently being clarified with the Swedish Tax Authorities and, as a consequence, we do not currently offer the respective tax services.
We will continue to monitor the situation and provide more information as it becomes available.