Switzerland and Iran sign Protocol of Amendment to the DTA
Peter von Burg
On 3 June 2019, Switzerland and Iran signed an amendment protocol to the double taxation agreement (DTA) in the area of taxes on income and assets.
The Protocol of Amendment to the DTA with Iran implements the minimum standards in double taxation agreements and contains in particular a misuse clause.
An additional paragraph is added to Article 7 (Profits) and Article 9 (Affiliates), which generally provide for a period of five years for the adjustment or allocation of profits. In the case of Article 25 (Mutual agreement procedure), the mutual agreement system should in no case be implemented later than ten years after the end of the tax year in question. In addition, a provision on the exchange of information (Article 26) will be included in the DTA on request.
The cantons and interested business circles have welcomed the conclusion of the Protocol of Amendment. Before it can enter into force, it must be approved by the parliaments of both countries.
The corresponding press release of the Federal Department of Finance (FDF) is available here.
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