Switzerland and Ireland signed a protocol to amend the double taxation agreement (DTA) in the area of taxes on income and capital. It also inserts a new Article 26 into the DTA which contains provisions on the exchange of information in accordance with the international standard applicable at present.
Aside from an OECD administrative assistance clause, Switzerland and Ireland 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 10% in the capital of the distributing company, the dividends will be exempt from withholding tax. Also, there will be no withholding taxes on dividends paid to the national banks of the two countries or to pension funds.
The revision still has to be approved by both countries before it can come into force. The protocol, which was signed on 26 January in Dublin, is published on the Revenue website.