• Switzerland - Portugal
    Amending protocol signed

    26-06-2012

    Switzerland has signed an amending protocol to its Income Tax Treaty with Portugal on 25 June 2012.

    The provisions of the amending Protocol will take effect once the two countries exchange ratification instruments.

    As per the amending protocol the following changes are proposed:

    1. Dividends
      • 0% if the beneficial owner is a company which holds a stake of at least 25% for a minimum period of 2 years in the capital of the company paying the dividends.
      • 15% in all other cases.
    2. Interest and royalties paid between associated enterprises (stakes of 25% held for at least 2 years) will benefit from a 0% withholding tax rate from 1 July 2013.
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