Federal Council adopts dispatch on amendment of double taxation agreement with Serbia

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Federal Council adopts dispatch on amendment of double taxation agreement with Serbia

The Federal Council

Bern, 01.05.2024 - During its meeting on 1 May 2024, the Federal Council adopted the dispatch on the protocol of amendment, signed with Serbia, to the double taxation agreement (DTA) between Switzerland and Serbia and Montenegro. The protocol implements the Base Erosion and Profit Shifting (BEPS) minimum standards for double taxation agreements.

In particular, the protocol of amendment contains an abuse clause which refers to the main purpose of a tax arrangement or a transaction and thus ensures that the DTA is not abused. It also contains an administrative assistance clause in accordance with the international standard for the exchange of information upon request.

The DTA was concluded at a time when Serbia and Montenegro still formed a single state. The federation has since been dissolved and Serbia and Montenegro are now two separate states. The provisions of this protocol of amendment apply solely for Serbia, whereas the existing agreement continues to apply for Montenegro.

The cantons and interested business sectors have welcomed the conclusion of the protocol of amendment. It still has to be approved by the legislator in both countries before it can come into force.

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State Secretariat for International Finance SIF
Tel. +41 58 462 46 16, [email protected]

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The Federal Council
https://www.admin.ch/gov/en/start.html

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