Switzerland has 106 tax agreements in force, as reported in its response to the Peer Review questionnaire. Four of those agreements, the agreements with Kosovo*, Latvia, the United Kingdom and Zambia, comply with the minimum standard.

Switzerland signed the MLI in 2017 and deposited its instrument of ratification on 29 August 2019. The MLI entered into force for Switzerland on 1 December 2019. Switzerland has listed twelve of its agreements under the MLI and 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. Switzerland considers that the MLI amends a covered tax agreement like an amending protocol. An agreement with the other contracting jurisdiction on the precise wording of the amendments to the corresponding tax agreement through the MLI is therefore a requirement for Switzerland to include a tax agreement under the MLI.

Switzerland indicated in its response to the Peer Review questionnaire that it has entered or intends to enter into bilateral negotiations with more than 40 of its treaty partners:

  • Bilateral complying instruments have been signed with respect to its agreements with Iran*, Ireland, Korea, Kuwait*, the Netherlands, New Zealand, Norway, Sweden and Ukraine; and,

  • Bilateral negotiations would be used with respect to agreements with Albania, Algeria*, Armenia, Australia, Belgium, Bulgaria, Canada, China (People's Republic of), Colombia, Côte d’Ivoire, Croatia, Cyprus*, Denmark, Egypt, Estonia, Finland, France, Georgia, Germany, Greece, Hong Kong (China), Hungary, India, Indonesia, Israel, Jamaica, Japan, Kazakhstan, Kyrgyzstan*, Liechtenstein, Malaysia, Malta, Mongolia, Montenegro, Morocco, North Macedonia, Oman, Pakistan, Peru, Poland, Qatar, Romania, Russia, Serbia, Singapore, the Slovak Republic, Slovenia, Spain, Sri Lanka, Thailand, Trinidad and Tobago, Tunisia, the United Arab Emirates, the United States, Uruguay and Viet Nam.1

Switzerland also mentioned that it considered that there was 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).

Switzerland has made a reservation under the MLI that delays its entry into effect after completing its internal procedures for this purpose for each of its listed agreements.2 Switzerland notified that it completed its internal procedures for the entry into effect of the MLI with respect to its agreements with Luxembourg on 27 May 2020 and with respect to its agreements with the Czech Republic and Lithuania on 18 December 2020.

Switzerland is implementing the minimum standard through the inclusion of the preamble statement and the PPT.3

The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.

No jurisdiction has raised any concerns about their agreements with Switzerland.


← 1. Each of them has been contacted with a proposal for a protocol amending the tax agreement and corresponding negotiations have been suggested.

← 2. The reservation was made under Article 35(7)(a) of the MLI.

← 3. 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).

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