SIF publishes agreement on DTA between Switzerland and Colombia
Silvia Hunziker
On 5 March 2019, the State Secretariat for International Financial Matters (SIF) published a Memorandum of Understanding (MoU) on the Agreement between the Swiss Confederation and the Republic of Colombia on the Avoidance of Double Taxation in the Area of Taxes on Income and Capital of 26 October 2007 (DTA Switzerland-Colombia).
The agreement refers to the difficulties and uncertainties which have arisen in connection with the issuing of the Swiss forms in relation to Art. 10 para. 2 (dividends) and Art. 11 para. 2 (interest) of the DTA Switzerland-Colombia.
The agreement describes in detail how Colombia should issue the residence certificates in this context. This confirmation should state at what time or period the taxpayer was resident in Colombia for tax purposes and when the confirmation was issued.
The agreement should be applicable to all pending and future applications. Applications that have already been rejected due to the lack of a confirmation of tax residence on the Swiss form should be reviewed again on condition that a new application is submitted. The statute of limitations shall be calculated on the basis of the first application.
.
