The U.S. IRS has announced a competent authority arrangement with Switzerland regarding the implementation of the arbitration process provided for in paragraphs 6 and 7 of Article 25 of the 1996 income tax treaty between the two countries. The agreement covers various aspects of arbitration, including the application of the arbitration procedure, assistance by competent authorities, cases eligible and not eligible for arbitration, the commencement date of arbitration procedures, confidentiality, and the appointment and eligibility of arbitrators. The agreement was announced in IRS Bulletin No. 2020–35, which includes the full text of the agreement.