Switzerland
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Zurich GMT +1
EY
Maagplatz 1
P.O. Box
CH-8010 Zurich Switzerland
+41 (58) 286-31-11
Fax: +41 (58) 286-30-04
Head of Tax and Legal – Switzerland
Roger Krapf
+41 (58) 286-21-25
Email: roger.krapf@ch.ey.com
Christian Röthlin, +41 (58) 286-35-38 Financial Services
Email: christian.roethlin@ch.ey.com
International Tax and Transaction Services – International Corporate Tax Advisory
Jan Bertini
Daniel Gentsch
Hartwig Hoffmann
Sarah Lacher
Dr. Georg Lutz
Sita Mahawattage
Marco Mühlemann
Dr. Thomas Semadeni
+41 (58) 286-48-61
Email: jan.bertini@ch.ey.com
+41 (58) 286-36-13
Email: daniel.gentsch@ch.ey.com
+41 (58) 286-75-71
Email: hartwig.hoffmann@ch.ey.com
+41 (58) 286-34-20
Email: sarah.lacher@ch.ey.com
+41 (58) 286-44-16
Email: georg.lutz@ch.ey.com
+41 (58) 289-75-39
Email: sita.mahawattage@ch.ey.com
+41 (58) 286-83-91
Email: marco.muehlemann@ch.ey.com
+41 (58) 286-31-75
Email: thomas.semadeni@ch.ey.com
International Tax and Transaction Services – Operating Model Effectiveness and Transfer Pricing
Fabian Berr
Céline Bulard
Nathan Richards
Hubert Stadler
Ramon Taboada Souza Neto
+41 (58) 286-33-80
Email: fabian.berr@ch.ey.com
+41 (58) 286-34-75
Email: celine.bulard@ch.ey.com
+41 (58) 286-41-90
Email: nathan.richards@ch.ey.com
+41 (58) 286-49-41
Email: hubert.stadler@ch.ey.com
+41 (58) 286-33-56
Email: ramon.taboada@ch.ey.com
International Tax and Transaction Services – Global Tax Desk Network
Jason Gyamerah,
United States –
Private Client Services
Michael Parets,
United States –
Private Client Services
+41 (58) 286-36-54
Email: jason.gyamerah@ch.ey.com
+41 (58) 286-39-92
Email: michael.parets@ch.ey.com
Berne
Ernst & Young
Schanzenstrasse 4a
CH-3008 Berne
Switzerland
+41 (58) 286-61-11
Fax: +41 (58) 286-68-18
International Tax and Transaction Services – International Corporate Tax Advisory
Martin Baumgartner
Conradin Mosimann
Business Tax Advisory
Frédéric Bonny
Matthias Britsch
Stefan Kissling
Martin Kistler
Hanspeter Saner
Global Compliance and Reporting
Reto Schwerzmann
Legal Services
Marc Gugger,
Labor and Employment Law
Andreas Jaeggi,
+41 (58) 286-62-32
Email: martin.baumgartner@ch.ey.com
+41 (58) 286-67-18
Email: conradin.mosimann@ch.ey.com
+41 (58) 286-62-02
Email: frederic.bonny@ch.ey.com
+41 (58) 286-65-37
Email: matthias.britsch@ch.ey.com
+41 (58) 286-61-07
Email: stefan.kissling@ch.ey.com
+41 (58) 286-62-06
Email: martin.kistler@ch.ey.com
+41 (58) 286-64-93
Email: hanspeter.saner@ch.ey.com
+41 (58) 286-63-69
Email: reto.schwerzmann@ch.ey.com
+41 (58) 286-61-90
Email: marc.gugger@ch.ey.com
+41 (58) 286-62-70 Digital Law/Data Protection
Indirect Tax
Henrik Dummermuth
Geneva
Ernst & Young
Place de Pont-Rouge 1
P.O. Box 1575
CH-1211 Geneva 26 Switzerland
Email: andreas.jaeggi@ch.ey.com
+41 (58) 286-62-38
Email: henrik.dummermuth@ch.ey.com
+41 (58) 286-56-56
Fax: +41 (58) 286-56-57
International Tax and Transaction Services – International Corporate Tax Advisory
Alexander Douglas
Sarah Drye
Eric Duvoisin
Hugo Lombardini
Karen Simonin
Elodie Tonetto
+41 (58) 286-58-50
Email: alexander.douglas@ch.ey.com
+41 (58) 286-57-34
Email: sarah.drye@ch.ey.com
+41 (58) 286-58-32
Email: eric.duvoisin@ch.ey.com
+41 (58) 286-58-57
Email: hugo.lombardini@ch.ey.com
+41 (58) 286-56-53
Email: karen.simonin@ch.ey.com
+41 (58) 286-53-43
Email: elodie.tonetto@ch.ey.com
International Tax and Transaction Services – Operating Model Effectiveness and Transfer Pricing
Amandine Bourlon
Xavier Eggspuhler
Benjamin Gabelle
Ioseb Nutsubidze
Francisco Palacios,
Financial Services
Madalina Pirvu
Jeroen Truin
Indirect Tax
Ashish Sinha
Business Tax Advisory
Blaise Eyraud
Jean-Marie Hainaut
Suzanne Lauritzen
Laila Rochat
Global Compliance and Reporting
Sandrine Berrette
Sandra Piscitelli
Legal Services
Silvia Devulder,
+41 (58) 286-55-56
Email: amandine.bourlon@ch.ey.com
+41 (58) 286-55-47
Email: xavier.eggspuhler@ch.ey.com
+41 (58) 286-58-82
Email: benjamin.gabelle@ch.ey.com
+41 (58) 286-58-03
Email: ioseb.nutsubidze@ch.ey.com
+41 (58) 286-58-48
Email: francisco.palacios@ch.ey.com
+41 (58) 286-57-03
Email: madalina.pirvu@ch.ey.com
+41 (58) 286-57-24
Email: jeroen.truin@ch.ey.com
+41 (58) 286-59-06
Email: ashish.sinha@ch.ey.com
+41 (58) 286-57-72
Email: blaise.eyraud@ch.ey.com
+41 (58) 286-58-51
Email. jean-marie.hainaut@ch.ey.com
+41 (58) 286-57-88
Email: suzanne.lauritzen@ch.ey.com
+41 (58) 286-56-08
Email: laila.rochat@ch.ey.com
+41 (58) 286-56-25
Email: sandrine.berrette@ch.ey.com
+41 (58) 286-55-30
Email: sandra.piscitelli@ch.ey.com
+41 (58) 286-38-03 Financial Services
Aurélien Muller
Email: silvia.devulder@ch.ey.com
+41 (58) 286-57-35
Email: aurelien.muller@ch.ey.com
People Advisory Services Tax – Global Mobility and Rewards
Radmilla Del Pozzo,
Rewards
Hugh Docherty
Lausanne
Ernst & Young
Avenue de la Gare 39a
P.O. Box
CH-1002 Lausanne Switzerland
Business Tax Advisory
Christian Aivazian
+41 (58) 286-56-98
Email: radmilla.delpozzo@ch.ey.com
+41 (58) 286-43-42
Email: hugh.docherty@ch.ey.com
+41 (58) 286-51-11
Fax: +41 (58) 286-51-01
GMT +1
+41 (58) 286-51-23
Email: christian.aivazian@ch.ey.com
a Swiss company or derived from foreign real estate is excluded from taxable income. Losses incurred by a foreign permanent establishment are deductible from taxable income. However, if a foreign permanent establishment of a Swiss company realizes profits in the seven years following the year of a loss and if the permanent establishment can offset the loss against such profits in the foreign jurisdiction, the Swiss company must add the amount of losses offset in the country of the permanent establishment to its taxable income in Switzerland.
A company not resident in Switzerland is subject to Swiss income tax if it has a permanent establishment or real estate in Switzerland.
Tax Harmonization Act. The Tax Harmonization Act (THA) sets certain minimum standards for cantonal/communal taxes. However, cantonal/communal tax rates are not harmonized under the THA.
Rates of corporate tax. The federal corporate income tax is levied at a flat rate of 8.5% of the taxable income. Because taxes are deductible in Switzerland, the federal corporate income tax rate on pre-tax income is approximately 7.8%.
Cantonal/communal tax rates vary widely. The cantonal/communal tax rates are usually a certain percentage (known as “multipliers”) of the relevant cantonal statutory tax rates. The total tax liability consisting of federal and cantonal/communal taxes ranges from 11% to 21% (rounded numbers) of the pre-tax income, depending on the canton and commune in which the taxable entity is located.
Tax incentives. In Switzerland, tax incentives are granted to companies either by the cantons or by both the cantons and the federation if the respective conditions are met.
Patent box at the cantonal level. A patent box, which is compliant with the Organisation for Economic Co-operation and Development (OECD), is available at the cantonal level. Subject to the nexus approach, qualifying income derived from patents and equivalent rights is eligible for a relief of 10% to 90% (varies among the cantons). On entry in the patent box, the previously deducted research and development (R&D) expenditures are recaptured and taxed at the cantonal level.
R&D super deduction at the cantonal level. In certain cantons, an incremental deduction between 20% and 50% of the taxpayer’s qualifying R&D expenditures can be applied (varies among the cantons). Only expenditures incurred in connection with R&D activities performed in Switzerland, either by the taxpayer or by related or unrelated parties, are eligible for the super deduction.
Notional interest deduction for taxpayers domiciled in the canton of Zurich. There is a grant of a notional interest deduction (NID), which is an imputed interest deduction on surplus equity. Surplus equity represents the portion of equity that exceeds the core equity required to conduct the business activity of the entity.
Immigration step-up at the federal and cantonal level. Hidden reserves, including self-created goodwill, can be disclosed for tax purposes on the immigration of assets, businesses or functions
from abroad to Switzerland. The disclosed hidden reserves must be amortized within the ordinary amortization periods, while disclosed self-created goodwill must be amortized within 10 years.
Overall cantonal tax relief limitation at the cantonal level. The cantonal tax incentives, such as patent box, R&D super deduction and NID, are subject to a maximum relief limitation of up to 70% of the taxable profit (varies among the cantons).
Tax holidays. In Switzerland, tax holidays are granted to companies either by the cantons or by both the cantons and the federation. Except for the limitation on the duration of tax holidays to a maximum period of 10 years, the cantons are autonomous in granting cantonal/communal tax holidays to the following:
• Newly established enterprises
• An already established enterprise that makes a material change in its operations
Tax holidays at the federal level require approval of the federation. Tax holidays at the federal level are governed by the federal law on regional policy, which is based on the following key factors:
• Establishment of new business activities in a qualifying area of economic development
• The performance by the applying company of industrial activities or services that have a close nexus to production activities
• Creation of new jobs or maintaining of jobs
• Particular economic relevance of the planned project for the area
The maximum amount of the federal tax relief is determined by the number of newly created or maintained jobs. Productionrelated service providers are eligible for a federal tax holiday if they create at least 10 new jobs within the first 5 years. No such limitation applies to industrial enterprises.
Federal and cantonal/communal tax holidays are typically subject to clawback provisions. The clawback clause is generally triggered if the conditions for the tax holidays are no longer met (for example, the envisaged number of jobs have not been created or have not been maintained within the relevant time frame).
Capital gains. Capital gains are generally taxed as ordinary business income at regular income tax rates. Different rules may apply to capital gains on real estate or to real estate companies at the cantonal/communal level.
Capital gains derived from dispositions of qualifying investments in subsidiaries qualify for the participation exemption. Under the participation exemption rules for capital gains, the parent company must sell a shareholding of at least 10% and, at the time of the disposal, it must have held the shares for at least one year (for further details regarding the participation exemption, see Dividends).
Administration. Income tax is generally assessed on the income for the current fiscal year, which corresponds to the corporation’s financial year. The financial year does not need to correspond with the calendar year. Corporations are required to close their books once a year and file annual returns. This rule does not
Relief for losses. Income of the current year may be offset against losses incurred in the preceding seven years, to the extent that such losses have not yet been used to absorb profits of prior years. No loss carryback is allowed.
Groups of companies. Except for value-added tax purposes, the concept of a consolidated or group return is unknown in Swiss tax law. Each corporation is treated as a separate taxpayer and files its own return.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax
Value-added tax (VAT), on deliveries of goods and services, including imports of goods and the purchase of services and (in very specific cases) of goods from foreign businesses that are not registered for VAT in Switzerland
and lodging services (overnight
Preferential rate (applicable to items such as foodstuffs, farming supplies, agricultural products,
Cantonal/communal rate; varies among the cantons and may also depend on the multiplier applied by the canton/commune (the cantons can provide for certain relief measures including the credit of the corporate income tax against the cantonal/communal equity tax)
to 0.5
Company pension fund; rate varies by plan (compulsory and optional), gender and age of employee; paid by Employer (must bear at least one-half of the contribution) 3.5 to 9
Nature of tax
Maternity insurance (only for some cantons) Various Accident insurance; rates vary depending on extent of coverage and the risk of the business; imposed on annual gross salary of up to CHF148,200
Occupational; paid by employer; for extremely high risks, rates vary depending on various factors (for example, industrial sector of the employer)
Non-occupational; employer may elect to charge all or part of these premiums to employees; for extremely high risks, rates vary depending on various factors (for example, industrial sector of the employer)
Stamp duties
Various
Various
One-time capital contribution tax, on Swiss shares (the rate is 0% for shares issued within the scope of qualified mergers and reorganizations, as well as for financial reorganizations, provided specific requirements are met); for incorporations and capital increases, the first CHF1 million is exempt from tax 1
Securities turnover tax; on the sale or exchange of taxable securities involving a Swiss-registered securities dealer (as defined by the law) that acts in the capacity of a broker or dealer or that trades on its own account; the onus for payment of the securities turnover tax is on the Swiss securities dealer, but it is customary that the securities turnover tax be charged to the ultimate buyer and/or seller; several types of parties are exempt, including investment fund managers and foreign companies listed on a recognized stock exchange; several types of transactions are exempt, including the brokering of foreign bonds between foreign parties and qualifying internal group transactions
E. Miscellaneous matters
Debt-to-equity rules. Under the federal thin-capitalization guidelines, which are also applied by most cantons, the minimum capitalization is calculated based on the maximum indebtedness of all of the assets. For each type of asset, only a specified percentage may be financed with debt from related parties (directly or indirectly). Consequently, the debt-to-equity ratio results from the sum of the maximum amount of indebtedness of all of the assets. The following are examples of the maximum percentages of indebtedness:
being. Accompanying the ordinance, an explanatory statement was released that suggests that an application of the International Top-up Tax as of 1 January 2025 is likely. Nevertheless, this scenario is greatly contingent upon the global implementation landscape.
The GloBE rules will only apply to in-scope MNEs. The rules apply in addition to the ordinary corporate income tax system, which is not adjusted and applies unchanged in a first step. In a second step, the Swiss Top-up Tax will apply if the covered taxes from the ordinary corporate tax system aggregated for all Swiss group entities of an in-scope MNE group, divided by the respective aggregated GloBE Income or Loss, results in a GloBE Effective Tax Rate below 15%. It is anticipated that the Swiss Top-up Tax should qualify for the QDMTT Safe Harbour. Consequently, no additional IIR and UTPR calculations should be necessary for Swiss in-scope entities abroad.
For the latest information, please see the BEPS 2.0 – Pillar Two Developments Tracker (ey-beps-2-0-pillar-two-developmentstracker.pdf).
F. Treaty withholding tax rates
(cccc)
Barbados (tttt) 15/25 (uuuu) 0 0
Belarus 5 (d) 0/5/8 (gggg) 0
Belgium 0 (gg)(hh) 0/10 (gg)(ll) 0
Belize (tttt) 15/25 (uuuu) 0 0
Brazil 0/10/15 (qqqq) 0/10/15 (rrrr) 0
British Virgin Islands (tttt) 15/25 (uuuu) 0
Bulgaria 0 (x)(gg) 0/5 (gg)(ttt)
Canada 0/5 (f)(xx) 0/10 (yy) 0
Chile 15 5/15 (vv) 0
China Mainland (w) 0/5 (bbbb) 0/10 (dddd) 0
Colombia 0 (t) 0/10 (hhhh) 0
Côte d’Ivoire 15 15 0
Croatia 5 (d)(gg) 5 (gg) 0
Cyprus 0 (gg)(sss) 0 (gg) 0
Czech Republic 0 (gg)(vvv) 0 (gg) 0
Denmark (rr) 0 (h)(gg) 0 (gg) 0
Dominica (tttt) 15/25 (uuuu) 0
Ecuador 15 0/10 (ll) 0
Egypt 5 (d) 0/15 (m) 0
Estonia 0 (dd)(gg) 0 (gg) 0
Ethiopia 5/15 (vvvv) 5 0
Residence of Dividends Interest (a) Royalties (b) recipient
Faroe Islands (rr) 0 0 0
Finland 0 (gg)(oo) 0 (gg) 0
France 0 (e)(gg) 0 (gg) 0
Gambia (tttt) 15/25 (uuuu) 0 0
Georgia 0 (oo) 0 0
Germany 0 (j)(gg) 0 (gg) 0
Ghana 5 (g) 0/10 (ll) 0
Greece 5 (d)(gg)(zz) 7 (gg) 0
Grenada (tttt) 15/25 (uuuu) 0 0
Hong Kong 0 (ppp) 0 0
Hungary 0 (gg)(www) 0 (gg) 0
Iceland 0 (nn) 0 0
India (ss) 5 (ss) 0/10 (cc) 0
Indonesia 10 (d) 10 0
Iran 5 (i) 0/10 (r) 0
Ireland 0 (gg)(www) 0 (gg) 0
Israel 5 (g) 5/10 (k) 0
Italy 15 (gg) 12.5 (gg) 0
Jamaica 10 (s) 0/10 (iiii) 0
Japan 0 (ww) 0 (ff) 0
Kazakhstan 5 (bb)(yyy) 10 0
Korea (South) 5 (g) 0/5/10 (k)(iii) 0
Kosovo 0/5 (yyy)(mmmm) 0/5 (llll) 0
Kuwait 15 10 0
Kyrgyzstan 5 (d) 5 0
Latvia 0 (dd) 0/10 (qq) 0
Liechtenstein 0 (eeee) 0 0
Lithuania 5 (o)(gg) 0/10 (gg)(iiii) 0
Luxembourg 0 (q)(gg) 0/10 (gg) 0
Malawi (tttt) 15/25 (uuuu) 0 0
Malaysia 5 (d) 10 0
Malta 0 (gg)(mmm) 0/10 (gg)(lll) 0
Mexico 0 (bb) 5/10 (p) 0
Moldova 5 (d) 0/10 (ll) 0
Mongolia 5 (d) 0/10 (ll) 0
Montenegro 5 (t) 10 0
Montserrat (tttt) 15/25 (uuuu) 0 0
Morocco 7 (d) 10 0
Netherlands (kkkk) 0 (h)(gg) 0 (gg) 0
New Zealand 15 10 0
North Macedonia 5 (d) 0/10 (cc) 0
Norway 0 (y) 0 0
Oman 0/5 (g)(kkk) 0/5 (llll) 0
Pakistan 10 (ee) 10 0
Peru 10 (zzz) 10/15 (aaaa) 0
Philippines 10 (y) 10 0
Poland 0 (gg)(tt) 0/5/10 (c)(gg) 0
Portugal 5 (d)(gg) 10 (gg)(dddd) 0
Qatar 5 (pp) 0 0
Romania 0 (gg)(ii) 0/5 (gg)(nnn) 0
Russian Federation 0/5 (hhh)(ooo) 0 0
St. Kitts and Nevis (tttt)15/25 (uuuu) 0 0
(ff) A 10% rate applies to interest payments if the interest payments are determined based on the following:
• Revenue, sales, income, profits or other cash flows of the debtor or a related party
• Value adjustments of assets of the debtor or a related party
• Dividend payments or distributions of a partnership
• Similar payments of the debtor or related parties
The 0% rate applies to all other interest payments.
(gg) A 0% rate may apply under the Switzerland-EU agreement (see the paragraph preceding the treaty withholding tax rate table). The rates shown in the table are the treaty withholding tax rates.
(hh) The 0% rate applies if the recipient is a company that owns directly at least 10% for a period of at least one year of the capital of the company paying the dividends or if the recipient is a pension fund or pension scheme, provided that the dividends do not result from a business activity or are paid by a related company. The 15% rate applies to other dividends.
(ii) The 0% rate applies if the recipient is a company (other than a partnership) that owns directly at least 25% of the capital of the company paying the dividends, a governmental institution, a pension fund or a central bank authority. A 15% rate applies to other dividends.
(jj) The 5% rate applies if the corporate recipient of the dividends holds a shareholding of at least 20% in the distributing entity and has invested at least USD200,000 in the country of the distributing entity. The treaty withholding tax rate is increased to 15% if the shareholding is less than 20%.
(kk) The 0% rate applies to interest paid to certain government agencies or in connection with the purchase of industrial, commercial or scientific equipment on credit. The 5% rate applies to interest paid to banks or in connection with the purchase of goods on credit. The 10% rate applies to other interest.
(ll) The 0% rate applies to the following interest payments:
• Interest paid on loans granted by a company of the other state
• Interest paid to pension funds or pension schemes, provided that the interest does not result from a business activity or is paid by a related company
• Interest paid to the other contracting state, one of its political subdivisions, to local authorities or to a statutory body
A 10% rate applies to all other interest payments.
(mm) The 0% rate applies if the beneficial owner of the dividends is one of the following:
• A company that is a resident of the other contracting state that holds directly at least 50% of the capital of the paying company for at least 365 days including the day of the dividend payment (in the case of a merger, demerger or conversion, the holding period continues to run) and that has a stake in the capital of the dividend paying company at the time of the dividend payment amounting to more than CHF2 million (or the equivalent amount in foreign currency)
• A pension fund or scheme
• The central bank of the other contracting state
The 5% rate applies if the beneficial owner of the dividends is a company that is a resident of the other contracting state that holds directly at least 10% of the capital of the paying company for at least 365 days including the day of the dividend payment (in case of a merger, demerger or conversion the holding period continues to run) and that has a stake in the capital of the dividend paying company at the time of the dividend payment amounting to more than CHF100,000 (or the equivalent amount in foreign currency). The 15% rate applies to all other dividend payments.
(nn) The 0% rate applies if the beneficial owner of the dividends is one of the following:
• A company (other than a partnership) that is a resident of the other contracting state and that holds directly at least 10% of the capital in the company paying the dividends for at least one year before the payment of the dividend
• A pension scheme
• The central bank of the other contracting state
(oo) The 0% rate generally applies if the shareholding of a corporate recipient of dividends is at least 10%. The rate is increased to 10% if the shareholding of a corporate recipient is less than 10%.
(pp) A 0% rate applies to dividends paid to the other contracting state or a political subdivision or local authority thereof, the central bank or pension funds. The 5% rate applies to dividends paid to corporate recipients if the
shareholding is at least 10%. A 10% rate applies if the recipient is an individual with a shareholding of at least 10%. For other dividends, the rate is 15%.
(qq) The 0% rate applies if the recipient of the interest is a company (other than a partnership).
(rr) The treaty between Denmark and Switzerland was extended to the Faroe Islands as of 22 September 2009. The extension and the revised protocol between Denmark and Switzerland entered into force in November 2010.
(ss) On 10 October 2011, an amending protocol entered into force. The protocol did not change the withholding tax rates. However, if after the date of signing of the amending protocol, India and a third state that is an OECD member sign a convention, agreement or protocol and if under this convention, agreement or protocol, India limits its taxation at source of dividends, interest, royalties or fees for technical services to a rate lower than the rate provided for in the double tax treaty between Switzerland and India, the lower rate will also apply under the double tax treaty between Switzerland and India, effective from the date on which such convention, agreement or protocol enters into force.
As a result, the following rate reductions apply:
• The withholding tax rate on dividends paid to corporate recipients if the shareholding is at least 10% was lowered from 10% to 5%. The lower rate applies retroactively from 5 July 2018 when Lithuania became a member of the OECD.
• The withholding tax rate on dividends paid to other recipients was lowered from 10% to 5%. The lower rate applies retroactively from 28 April 2020 when Colombia became a member of the OECD.
(tt) The 0% rate applies if the dividends are paid to corporations with a shareholding of at least 10% in the capital of the payer and the shareholding is held for at least two years or if the dividends are paid to pension funds or similar institutions. A 15% rate applies in all other cases.
(uu) The 0% rate applies to interest paid to the other contracting state or certain government agencies of the contracting state or in connection with financing transactions, the purchase of industrial, commercial or scientific equipment or the construction of industrial, commercial, scientific or public facilities on credit. The 10% rate applies to all other interest.
(vv) The 5% rate applies to interest paid on bank and insurance loans, on bonds and other securities that are traded on a stock exchange and in certain other special transactions. The 15% rate applies to all other interest payments.
(ww) The 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is either of the following:
• A company that has owned directly or indirectly shares representing at least 10% of the capital or voting power of the company paying the dividends
• A pension fund or scheme
A 10% rate applies to all other dividends.
(xx) The 0% rate applies to dividends that are paid to the Bank of Canada or qualifying pension schemes.
(yy) The 0% rate applies to interest payments if the beneficial owner of the interest is a resident of Canada and is not related to the payer.
(zz) The 0% rate applies if the beneficial owner of the dividends is the other contracting state, a political subdivision or a local authority of the other contracting state or a pension fund or scheme.
(aaa) The 0% rate applies to dividends paid to the Monetary Authority of Singapore or the Government of Singapore Investment Corporation Pte Ltd. The 5% rate applies to dividends paid to a corporation (other than a partnership) holding directly at least 10% of the capital of the company paying the dividends. A 15% rate applies to other dividends.
(bbb) The 0% rate applies to interest paid by a banking enterprise to a banking enterprise in the other contracting state or interest arising in Switzerland and paid to the Monetary Authority of Singapore. The 5% rate applies to other interest.
(ccc) The 0% rate applies to dividends paid to the respective national banks or certain pension funds listed in the protocol. The 5% rate applies if the recipient is a company that owns directly at least 10% for a period of at least one year of the capital of the company paying the dividends. A 15% rate applies to other dividends.
(ddd) The 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is either of the following:
• A company (other than a partnership) that has owned directly or indirectly shares representing at least 10% of the capital or voting power of the company paying the dividends
• A pension fund
A 15% rate applies to other dividends.
• Interest paid between companies that are associated by a direct stake of at least 25% or by a direct holding of a third company (resident in the EU or Switzerland) of at least 25% of the capital of both companies
The 5% rate applies to other interest payments.
(yyy) A 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is one of the following:
• A pension fund or scheme
• The central bank
(zzz) The 10% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is a company (other than a partnership) that holds directly at least 10% of the capital and of the voting power of the company paying the dividends. A 15% rate applies to other dividends.
(aaaa) The 10% rate applies to the following interest payments:
• Interest paid in connection with the sale on credit of industrial, commercial or scientific equipment
• Interest paid on bank loans
The 15% rate applies to other interest payments.
(bbbb) The 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is one of the following:
• The government of the other state, or a political subdivision or local authority thereof
• An institution or fund wholly owned by that other state as agreed by mutual agreement of the competent authorities of the contracting states
• The central bank
The 5% rate applies if the recipient is a company (other than a partnership) that owns directly at least 25% of the capital of the company paying the dividends. A 10% rate applies to other dividends.
(cccc) The 0% rate applies to dividends if the beneficial owner of the dividends is one of the following:
• A corporation of a listed group holding at least 80% of the voting power of the payer
• A pension scheme
• The central bank
• A contracting state, political subdivision or local authority thereof (including a government investment fund)
The 5% rate applies to dividends paid to a corporation holding at least directly 10% of the voting power of the payer. A 15% rate applies to all other dividends.
(dddd) The 10% rate applies to interest payments. However, exemptions apply to, among others, the following:
• The government of the other contracting state, and several governmental bodies and institutions thereof
• The national bank
(eeee) The 0% rate applies to dividends if the beneficial owner of the dividends is one of the following:
• A corporation that directly holds at least 10% of the capital in the company paying the dividend for at least one year before the payment of the dividends
• A pension scheme
• A contracting state, political subdivision or local authority thereof
A 15% rate applies to all other dividends.
(ffff) The 0% rate applies to interest if the beneficial owner is a resident of the other contracting state and is in one of the following categories:
• Bodies exercising governmental functions and banks performing central bank functions
• Financial institutions that are unrelated to and dealing independently with the payer
• Complying Australian superannuation funds and tax-exempt Swiss pension schemes
A 10% rate applies to other interest payments.
(gggg) The 0% rate applies to the following interest payments:
• Interest on loans approved by the government
• Interest income derived from sales on credit of industrial, medical or scientific equipment
• Interest on bonds issued by a contracting state or a political subdivision or local authority thereof
The 5% rate applies to interest on bank loans. The 8% rate applies to other interest payments.
(hhhh) The 0% rate applies if any of the following circumstances exist:
• The beneficial owner of the interest is the contracting state or a political subdivision or local authority thereof.
• The interest is paid in connection with the sale on credit of goods, merchandise or any equipment.
• The interest is paid on bank loans. A rate of 10% applies to other interest payments.
(iiii) The 0% rate applies to interest in connection with bonds, debentures or other similar obligations of the government or of a political subdivision or local authority thereof and in certain other special cases. The 10% rate applies to other interest payments.
(jjjj) The 0% rate applies to interest on certain loans guaranteed, insured or financed by the contracting state. The 10% rate applies to other interest.
(kkkk) Special rules apply to for collective-investment vehicles regarding dividend and interest payments.
(llll) The 0% rate applies to the following interest payments:
• Interest paid in connection with the sale on credit of equipment, merchandise or services
• Interest paid on bank loans
• Interest paid with respect to pension schemes
• Interest paid to the government of the other state, a political subdivision or local authority thereof, or the central bank
• Interest paid on intercompany loans
The 5% rate applies to other interest payments.
(mmmm) The 5% rate applies if, at the time the dividends become due, the corporate recipient of the dividends has directly held a shareholding of at least 25% in the distributing entity for more than a year. For the purpose of the holding period, prior restructurings are disregarded. The treaty withholding tax rate is 15% if this condition is not met.
(nnnn) The 0% rate applies to dividends paid to individual pension institutions (that is, in Switzerland, pillar 3a institutions). The 5% rate applies to dividends paid to corporations with a shareholding of at least 10% in the payer. A 15% rate applies to other dividends.
(oooo) The 0% rate applies if any of the following circumstances exist:
• The beneficial owner of the interest payment is the contracting state, a political subdivision or local authority thereof, or the central bank.
• The interest is paid by the contracting state or a political subdivision or local authority thereof.
• The interest is paid with respect to a loan, debt claim or credit that is owed to, or made, provided, guaranteed or insured by, that state or a political subdivision, local authority or export financing agency thereof.
The 5% rate applies to other interest payments.
(pppp) The 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is one of the following:
• The government of the other state, or a political subdivision or local authority thereof
• The central bank
• A pension fund or scheme
• An investment authority or another institution recognized by the contracting state and established by the government of the other state, or a political subdivision or local authority thereof
The 5% rate applies to dividends if the beneficial owner is a company (other than a partnership) with a shareholding of at least 10% of the payer’s capital. The 15% rate applies to other dividends.
(qqqq) A 0% rate applies to dividends if the beneficial owner is a resident of the other contracting state and is either of the following:
• Certain pension funds or schemes
• The central bank
The 10% rate applies to dividends if the beneficial owner is a company (other than a partnership) owning directly at least 10% of the capital of the paying company for at least a year. The 15% rate applies to other dividends.
(rrrr) The 0% rate applies to the following interest payments:
• Interest paid with respect to certain pension schemes
• Interest paid to the government of the other state, a political subdivision or local authority thereof, or the central bank
The 10% rate applies to interest payments if the beneficial owner is a bank; the loan is used for the financing of equipment or investment projects; and the loan has a term of at least five years. The 15% rate applies to other interest payments.