Portugal and Switzerland: protocol to treaty signed – details
July 2, 2012On 25 June 2012, Portugal and Switzerland signed an amending protocol to the Portugal–Switzerland Income and Capital Tax Treaty (1974) in Lisbon.
The protocol contains an exchange of information provision which is in line with article 26 of the OECD Model.
Furthermore, Switzerland and Portugal have agreed to limit the withholding tax on dividends as follows:
- 0% on corporate dividends (shareholding of 25% for at least two years)
- 0% on dividends paid to pension funds and national banks
- 15% in all other cases
The agreement also lays down the solutions contained in the agreement on the taxation of savings income for interest and royalty payments:
- Interest and royalties paid between associated enterprises (stakes of 25% held for at least two years) will benefit from a withholding tax rate of zero from 1 July 2013
The entry into force of the revised protocol requires the ratification by both countries.
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