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Protocol to Tax Treaty between Switzerland and the UK has Entered into Force

08 August 2019

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Treaty Development

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Switzerland-United Kingdom

The amending protocol to the 1977 income tax treaty between Switzerland and the United Kingdom entered into force on 16 July 2019. The protocol, signed 30 November 2017, includes the following changes: The preamble is updated in line with BEPS standards; Article 3 (General Definitions) is amended with the deletion of subparagraph (l) of paragraph 1, which concerns the definition of the term ‘conduit arrangement’; Paragraph 2 of Article 9 (Associated Enterprises) is replaced with updated provisions regarding appropriate (corresponding) adjustments by a Contracting State where an adjustment has been made in the other State; The individual limitation on benefits...