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Swiss Federal Council Approves Pending Protocol to Tax Treaty with Tajikistan

17 November 2022

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Treaty Development

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Switzerland-Tajikistan

The Swiss Federal Council has announced its adoption of the dispatch for the approval of the pending protocol to the 2010 income and capital tax treaty with Tajikistan. Changes made by the protocol include: The preamble is replaced in line with BEPS standards; Article 3 (General Definitions) is updated with respect to the definition of the term "competent authority" for both contracting states; 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...