Go-ahead given for entry into force of DTA between Switzerland and Argentina
Bern, 29.10.2015 - The double taxation agreement (DTA) with respect to taxes on income and capital between Switzerland and Argentina will enter into force on 27 November 2015 after the ratification procedure in Switzerland has been completed. It replaces the agreement of 1997 and is in line with the current international standard on the exchange of information.
On 28 October 2015, Stéphane Rossini, President of the National Council, submitted a diplomatic note in Buenos Aires in which notification is given that the national procedures in Switzerland have been completed. In accordance with the contractual text, the DTA between the two countries will thus enter into force 30 days after the last of the two notifications has been submitted. In this case, that means 30 days after the submission of the Swiss diplomatic note.
The new text puts an end to the agreement vacuum between Switzerland and the G20 member Argentina and there will once again be legal certainty for taxpayers. In 2012, Argentina terminated the agreement of 1997, which had been provisionally applied by both countries until then. On 20 March 2014, Switzerland and Argentina signed the new DTA in Bern, which was adopted by the Swiss parliament in June 2015. The referendum deadline of 100 days expired unused. The ratification procedures have also been completed in Argentina.
The purpose of the new agreement is the avoidance of double taxation with respect to taxes on income and on capital, particularly those on dividends, interest and royalty payments. It adopts the majority of the provisions of the former agreement and complies with the current international standard on the exchange of information upon request. The new agreement will be applicable from 1 January 2016, with the exception of taxes withheld at source, for which relief will already be applied in 2015 according to the agreement.
At the same time, the new DTA will strengthen the good economic relations between Switzerland and Argentina. Switzerland is Argentina's eighth-biggest investor. More than 70 Swiss companies with in total some 25,000 employees operate in Argentina.
To date, Switzerland has signed 53 DTAs and 9 tax information exchange agreements (TIEAs) that are in line with the international exchange of information standard, and of these, 42 DTAs (including the DTA with Argentina) and 7 TIEAs are in force.
Address for enquiries
Bilateral Tax Issues and Double Taxation Treaties Section, State Secretariat for International Financial Matters SIF
Tel. +41 58 462 71 29, firstname.lastname@example.org
Federal Department of Finance