Republic of Slovenia and Switzerland a have recently signed in Ljubljana a protocol to amend the double taxation agreement (DTA) between the two countries in the area of taxes on income and capital.
According to the Swiss Federal Department of Finance (FDF), the protocol contains provisions on the exchange of information in accordance with the international standard applicable at present and some adjustments to the existing agreement.
The new DTA will contribute to the further positive development of bilateral economic relations, the FDF says.
The FDF explains: “Aside from an OECD administrative assistance clause, Switzerland and Slovenia have agreed that both countries may levy withholding tax of no more than 15% on gross dividend amounts. If, however, a company holds a stake of at least 25% in the capital of the distributing company, the dividends will be exempt from withholding tax. In addition, no withholding tax will be due on dividend payments to pension funds.”
The FDF adds: “Interest and royalties paid amongst associated enterprises (stakes of 25% held for at least two years) will no longer be subject to tax at source in future. Finally, the revised agreement contains an arbitration clause.”
Following the negotiations, a report on the protocol to the DTA with Slovenia was submitted to the Swiss cantons and the business associations concerned for their comments. They approved the signing.
The revision still has to be approved by parliament in both countries before it can come into force.