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Protocol to Tax Treaty between Switzerland and the U.S. has Entered into Force

23 September 2019

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Treaty Development

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Switzerland-United States

The Swiss Federal Department of Finance has announced that the protocol to the 1996 income tax treaty with the United State entered into force on 20 September 2019. The protocol, signed 23 September 2009, provides new provisions in relation to a withholding tax exemption for dividends beneficially owned by a pension, retirement arrangement, or individual retirement plan, as well as the addition of arbitration provisions and the replacement of the exchange of information provisions. The protocol generally applies from 1 January 2020 in respect of withholding taxes and exchange of information, although the exchange of information changes apply for certain...