22 December 2016, the double tax treaty between Switzerland and Liechtenstein entered into force. It was signed on 10 July 2015 and is the first comprehensive tax treaty between the two countries. The provisions of the treaty will apply from 1 January 2017.
The new treaty replaces the current agreement of 22 June 1995 between Switzerland and Liechtenstein on various tax issues. It contains a provision on the exchange of information upon request.
Amendments to Switzerland’s double tax treaties with Norway and Albania entered into force on 6 December 6 and 1 December respectively. Both will apply from 1 January 2017.
The Norwegian protocol introduces a most favoured nation clause and inserts a new arbitration clause. It also amends the article on the exchange of information, at Norway’s request.
The Albanian protocol provides for the inclusion of a new arbitration clause. An ‘evolutionary’ clause on royalty payments means that any more advantageous agreements concluded by Albania with members of the European Union or the European Economic Area will also be applicable to cross-border dealings with Switzerland. It also updates the tax information exchange provisions and introduces a limitation on benefits clause.
Switzerland has currently signed 54 double tax treaties and 10 tax information exchange agreements (TIEAs) that are in line with the international standard on the exchange of information upon request.