Double Taxation Agreement between Uk and Switzerland
2. Where a Contracting State includes in the profits of an enterprise of that State the profits which an enterprise of the other Contracting State has been charged with taxing in that other State and the elements so included include income, deductions, revenues or expenses which would have been charged to the enterprise of the first-mentioned State if the conditions established between the two enterprises had been as follows: Between independent enterprises, the competent authorities of the States Parties may hold consultations with a view to reaching agreement on the correction of profits or losses in both States Parties. Double taxation CH-UK: 0.672.936.711 – 0.672.936.73 (de, fr, it) (7) The Convention of 17. October 1931 between the Government of the United Kingdom and the Swiss Federal Council on the reciprocal exemption from tax on profits or profits derived from an agency ends with the entry into force of this Agreement. (a)that the conventions provided for in the Convention have been concluded with the Swiss Federal Council with a view to alleviating double taxation with regard to income tax, corporation tax or capital gains tax and taxes of a similar nature imposed by Swiss law; and (4) The competent authorities of States Parties may communicate directly with each other with a view to reaching agreement within the meaning of the preceding paragraphs. The UK has entered into change agreements with a number of countries under the EU Directive on the taxation of savings income in the form of interest payments. The UK has also concluded a number of non-switching agreements under the EU Savings Tax Directive. 4. Where the amount of interest paid as a result of a special relationship between the payer and the beneficial owner or between the two and another person exceeds the amount that would have been agreed between the payer and the beneficial owner in the absence of such a relationship, the provisions of this Article shall apply only to the latter amount. In that case, the excess part of the payments, if treated as a dividend or a distribution of a company, shall be taxed in accordance with Article 10. 2. Subject to paragraphs 3, 4 and 6, where a resident of Switzerland generates income which may be taxed in the United Kingdom under United Kingdom law and the provisions of the Convention, Switzerland shall, subject to paragraphs 3, 4 and 6, exempt such income from Swiss tax, provided that such exemption applies to the profits referred to in Article 13 (4) only if: if these profits are taxed in Switzerland.
United Kingdom is demonstrated. The agreement also provides for similar taxes levied in the two signatory states. If you need more information about the Swiss tax system, you can contact our lawyers. DTAs also have an important function for investments of all kinds abroad, as they avoid double taxation of foreign investment profits and income. In addition, a DTA generally contains certain prohibitions of discrimination, a dispute settlement mechanism and a clause on the exchange of information upon request. (7) Where the Convention provides that, in the Contracting State in which such income arises, an exemption from income tax of any kind is permitted, that provision shall not be interpreted as meaning that such income is to be paid in full without deduction of withholding tax. Where the withholding tax has been deducted from such income, the tax authorities of the State in which an exemption is to be granted shall take the necessary steps to obtain an appropriate refund of the tax if the beneficial owner of the income proves to their satisfaction and within the time limits fixed in that State that he is entitled to the exemption. 6. The Convention shall not entitle an individual residing in a Contracting State whose income from the other Contracting State consists exclusively of dividends, interest or royalties (or only a combination thereof) to personal allowances, exemptions and reductions of the kind referred to in paragraphs 4 and 5 for the purposes of taxation in that other State. Desiring to conclude a convention for the avoidance of double taxation in the field of taxes on income, ARTICLE 23.
— (1) Nationals of a Contracting State may not be subject in the other Contracting State to any taxation or obligation different from or more onerous than the taxation and related requirements to which nationals of that other State are subject or exposed in the same circumstances. May be.. .