Amendments to the double taxation agreement with Norway in force

Bern, 22.12.2010 - Today, the protocol to amend the double taxation agreement (DTA) between Switzerland and Norway entered into force. Aside from a provision on the exchange of information in accordance with the OECD standard, the protocol contains a reduction in the stake required for exemption from withholding tax on dividends, a limit on the tax the source state is entitled to levy on pensions and most-favoured-nation treatment of Switzerland concerning an arbitration clause.

Switzerland and Norway informed one another via diplomatic channels that all of the conditions and legal procedures for the protocol's entry into force had been met. The amendments to the DTA thus entered into force today. The provisions of the DTA apply to dividends payable from 1 January 2011 and to pensions payable on or after 1 January 2011. In the case of administrative assistance in tax matters, the revised DTA will be applicable to tax years beginning on or after 1 January 2011.The revised DTA with Norway now contains withholding tax exemption on dividends in the case of a stake of at least 10%. In the earlier DTA, exemption from withholding tax was provided only on stakes of at least 20%. In addition, the source state now has the right to levy a tax of up to a maximum of 15% on pensions. Norway has also committed itself via a most-favoured-nation agreement to start negotiations on an arbitration clause as soon as it has negotiated a provision of this nature with another country.The Protocol of Amendment was signed in Oslo on 31 August 2009 and was approved by parliament on 18 June 2010. The referendum deadline expired unused on 7 October 2010.

Address for enquiries

Pascal Duss, Division for International Affairs, Federal Tax Administration, tel. 031 322 71 57