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Update - Protocol to Tax Treaty between Norway and Switzerland

22 July 2019

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Treaty Development

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Norway-Switzerland

A protocol to the 1987 tax treaty between Norway and Switzerland was signed on 20 June 2019. The protocol is the fourth to amend the treaty and includes the following changes: The preamble is updated in line with BEPS standards Article 9 (Associated enterprises) is amended with the addition of provisions for corresponding adjustments in cases where a Contracting State has included in the profits of an enterprise of that State the profits that would have accrued to that enterprise if the conditions of a transaction had been made at arm's length; Article 23 (Elimination of double taxation) is amended...