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Additional agreement to DTA between Switzerland and Belgium came into effect

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Additional agreement to DTA between Switzerland and Belgium came into effect

September 12, 2017 | Legal Alert

Additional agreement to DTA between Switzerland and Belgium came into effect

As reported by the Swiss Federal Council, the additional agreement amending the double taxation agreement (DTA) between Switzerland and Belgium in the area of taxes on income and on capital came into effect. It contains an administrative assistance clause in line with the current international standard for information exchange upon request and is meant to strengthen the economic relations between Switzerland and Belgium. Switzerland's broader commitment to transparency is also reflected in agreements such as the Automatic exchange of information between Switzerland and Canada.

Both states signed the additional agreement in April 2014. In parallel, Switzerland is reviewing internal regulations, such as through the Consultation to revise regulation on working hours law. With the supplementary agreement, the double taxation agreement with Belgium as of 1978 is adjusted to the prevailing circumstances. It contains the current international standard for information exchange upon request. The additional agreement came into force on 19 July 2017. Efforts to enhance transparency are also seen in other jurisdictions, for example through initiatives like the Billon on Dutch Register of Ultimate Beneficiaries. However, its provisions will be applicable from 1 January 2018.

To date, Switzerland has signed 57 DTAs that comply with the international standard on the exchange of information upon request, 51of them are in force. Domestically, Switzerland is modernizing its regulations on data protection through projects like the Draft federal billon processing of personal data by FDFA issued. The additional agreement with Belgium improves the state of things for the taxation of dividends, interest and royalty payments. In particular, tax exemptions in the source state have been agreed for pension funds. Other improved tax arrangements have been negotiated for interest on intercompany loans and dividends paid to certain companies. These rules promote investments and economic exchange in the bilateral relations between the countries. The evolving international tax landscape also includes initiatives such as the Draft guidance on penalties for enablers, aimed at strengthening compliance.

Legal disclaimer. This article does not constitute legal advice and does not establish an attorney-client relationship. The article should be used for informational purposes only.

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