Switzerland
A. Progress in the implementation of the minimum standard
Switzerland has 106 tax agreements in force, as reported in its response to the Peer Review questionnaire. Three of those agreements, the agreements with Kosovo*, Latvia and Zambia, comply with the minimum standard.
Switzerland signed the MLI in 2017, listing 14 tax agreements.
Switzerland is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1
The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.
Switzerland signed a bilateral complying instrument with respect to its agreements with Iran*, Ireland, Korea, the Netherlands, Norway, Sweden, Ukraine and the United Kingdom
Switzerland indicated in its response to the Peer Review questionnaire that it would only list an agreement under the MLI if it agrees with its treaty partner on how the MLI modifies their agreement. The agreement with Mexico will be added to Switzerland’s list of covered tax agreements under the MLI.
Switzerland further indicated in its response to the Peer Review questionnaire that it has entered or intends to enter into bilateral negotiations with more than 45 of its treaty partners.2 Bilateral negotiations would be used for agreements with Algeria*, Armenia, Australia, Belgium, Bulgaria, Canada, China, Colombia, Côte d’Ivoire, Croatia, Cyprus*, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Greece, Hong Kong (China), Hungary, Indonesia, Israel, Jamaica, Japan, Kazakhstan, Kuwait*, Kyrgyzstan*, Malaysia, Malta, New Zealand, Peru, Romania, Russia, Serbia, Singapore, the Slovak Republic, Slovenia, Spain, Sri Lanka, Tunisia, the United States, Uruguay and Viet Nam.
Switzerland mentioned that there is no concern for treaty shopping with respect to some of its treaty partners (Anguilla, Antigua and Barbuda*, Barbados, Belize, British Virgin Islands, Dominica, Gambia*, Grenada, Malawi*, Montserrat, Saint Kitts and Nevis, Saint Lucia, and Saint Vincent and the Grenadines).
B. Implementation issues
No jurisdiction has raised any concerns about their agreements with Switzerland.
Notes
← 1. For its agreements listed under the MLI, Switzerland is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).
← 2. Each of them has been contacted with a proposal for a protocol amending the tax agreement and corresponding negotiations have been suggested.