On 20 June 2019 in Oslo, Switzerland and Norway signed a protocol of amendment to the agreement for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the minimum standards for double taxation agreements.
In particular, the protocol of amendment contains an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused.
The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by parliament in both countries before it can come into force.
Address for enquiries:
Bilateral Tax Issues and Double Taxation Treaties Section
State Secretariat for International Finance SIF
Tel. +41 58 462 71 29
