• Switzerland - Australia
    New Tax Treaty Enters Into Force


    The new Income Tax Treaty between Switzerland and Australia entered into force on 14 October 2014. Its provisions will apply from 1 January 2015.

    The new treaty will replace the previous one of 1980.

    In accordance with the new treaty, the following withholding taxes will apply:

    • Dividends:
      • 0% for dividends paid to publicly listed companies, or subsidiaries thereof, or to unlisted companies in certain circumstances, that hold 80% or more of the paying company.
      • 0% for dividends paid to complying Australian superannuation funds and tax exempt Swiss pension schemes that hold no more than 10% direct voting power or capital in the company respectively for a period of at least 12 months prior.
      • 5% if the beneficial owner is a company which, in the case of Australia, holds directly at least 10% of the voting power in the company paying the dividends or in the case of Switzerland, holds directly at least 10% of the capital in the company paying the dividends.
      • 15% in all other cases.

    • Interest:
      • 0% on interest derived by a financial institution which is unrelated to and dealing wholly independently with the payer. For the purposes of this Article, the term "financial institution" means a bank or other enterprise substantially deriving its profits by raising debt finance in the financial markets or by taking deposits at interest and using those funds in carrying on a business of providing finance.
      • 0% on interest derived by a resident of Australia from the carrying on of complying superannuation activities.
      • 0% on interest derived by a Swiss pension scheme whose investment income is exempt from Swiss tax.
      • 10% in all other cases.

    • Royalties: 5%
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