The new Protocol to the UK/Switzerland double taxation agreement entered into force on 22 December 2008. The Protocol was signed in London on 26 June 2007. The following are the main changes to the Treaty:
- The elimination of taxation at source on dividends where the beneficial owner of the dividends has a substantial participation in the payer or is a pension scheme.
- In future information will be exchanged in cases of tax fraud or the like, and in cases involving holding companies.
The Protocol also contains measures relating to pensions. In future, lump sum payments may be taxed only by the state in which they arise. Also, pension contributions paid to a scheme recognised for tax purposes in one country may, under certain conditions, be deductible in the other country.
The Protocol is available here