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Amending Protocol to Tax Treaty between Malta and Switzerland has Entered into Force

06 December 2021

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Treaty Development

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Malta-Switzerland

The amending protocol to the 2011 income tax treaty between Malta and Switzerland entered into force on 3 November 2021. The protocol is the first to amend the treaty and includes the following changes: The preamble is replaced in line with BEPS standards; Article 7 (Business Profits) is amended with the addition of a new paragraph 7 providing that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of the Contracting States after 5 years from the end of the taxable year in which the profits would...