Switzerland and Slovenia sign revised double taxation agreement

Bern, 07.09.2012 - Today in Ljubljana, Switzerland and Slovenia signed a protocol to amend the double taxation agreement (DTA) in the area of taxes on income and capital. It contains provisions on the exchange of information in accordance with the international standard applicable at present and some adjustments to the existing agreement. The new DTA will contribute to the further positive development of bilateral economic relations.

Aside from an OECD administrative assistance clause, Switzerland and Slovenia have agreed that both countries may levy withholding tax of no more than 15% on gross dividend amounts. If, however, a company holds a stake of at least 25% in the capital of the distributing company, the dividends will be exempt from withholding tax. In addition, no withholding tax will be due on dividend payments to pension funds. The solutions contained in the agreement on the taxation of savings income will be adopted for interest and royalty payments, and are anchored in the double taxation agreement with Slovenia. Interest and royalties paid amongst associated enterprises (stakes of 25% held for at least two years) will no longer be subject to tax at source in future. Finally, the revised agreement contains an arbitration clause.

After negotiations finished, a report on the protocol to the DTA with Slovenia was submitted to the cantons and the business associations concerned for their comments. They approved the signing. The revision still has to be approved by parliament in both countries before it can come into force.

Address for enquiries

Pascal Duss, State Secretariat for International Financial Matters, tel. +41 (0)31 322 71 57, pascal.duss@sif.admin.ch