Federal Council adopts dispatch on revised double taxation agreement with Latvia

Bern, 28.06.2017 - On 28 June 2017, the Federal Council adopted the dispatch on a revised double taxation agreement (DTA) with Latvia with respect to taxes on income and capital. The dispatch was submitted to Parliament for approval.

Switzerland and Latvia signed a protocol of amendment to their DTA on 2 November 2016 in Riga. It contains several provisions from the OECD and G20 project to combat base erosion and profit shifting (BEPS project). Specifically, the protocol of amendment contains an abuse clause. This clause to prevent unwarranted claims of treaty benefits is consistent in its basic features with the abuse provisions agreed by Switzerland in most of its DTAs in recent years. Legal certainty will be increased for taxpayers with the inclusion of an arbitration clause.

Moreover, the DTA contains an administrative assistance clause in accordance with the current international standard for the exchange of information upon request. In particular, the agreement will introduce lower taxation of levies and distributed profits on qualified participations.

The cantons and the business circles concerned welcomed the conclusion of the protocol of amendment during the consultation procedure.

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


The Federal Council

Federal Department of Finance