Switzerland and Japan have agreed in principle on a revised double taxation agreement (DTA) in Tokyo. The Federal Council said today that Switzerland and Japan have held negotiations since 2008 on revising the double taxation agreement (DTA) which dates from 1971. Pursuant to the decision of the Federal Council on 13 March 2009, both countries agreed to also include extending administrative assistance in tax matters under Article 26 of the OECD Model Convention to the double taxation agreement.
In addition Switzerland and Japan agreed to make dividends on significant participations, certain types of interest in the finance sector and royalty payments exempt from withholding tax. This is in line with concerns raised by the Swiss economy.
Also announced in Bern today was that Switzerland and the Netherlands have finished negotiations on extending administrative assistance in tax matters under Article 26, and have initialled a revised DTA.
Japan and The Netherlands are the seventh and eighth country with which Switzerland has initialled a DTA with the extended administrative assistance clause. Others are Denmark, Luxembourg, Norway, France, Mexico and the USA.
The initialled text for both Japan and the Netherlands is still confidential and the cantons and the business associations will now have the opportunity to present their views. Thereafter, the Federal Council will decide on the authorisation for signing after which the agreements will be published.