Switzerland and Kosovo sign double taxation agreement

Bern, 26.05.2017 - On 26 May 2017 in Pristina, Switzerland and Kosovo signed a double taxation agreement (DTA) in the area of taxes on income and capital. The agreement will ensure legal certainty and a contractual framework that will have a beneficial impact on the two states' economic relations. No DTA has been in effect between them since 2011.

In particular, the agreement makes provision for dividends being taxed at source at a maximum rate of 15% and qualified participations being taxed at no more than 5%. Royalties will be taxed only in the beneficial owner's state of domicile.

In addition, the agreement contains an abuse clause in accordance with the recommendations of the OECD and G20 project to combat base erosion and profit shifting (BEPS project). Legal certainty will be increased for taxpayers with the inclusion of an arbitration clause. Moreover, the agreement contains an administrative assistance clause in accordance with the current international standard for the exchange of information upon request.

The cantons and business associations concerned welcomed the conclusion of the DTA with Kosovo. The agreement still has to be approved by parliament in both countries before it can come into force.

So far, Switzerland has signed 56 DTAs that are in line with the international standard on the exchange of information upon request; 50 of these 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, dba@sif.admin.ch


Federal Department of Finance