• Switzerland - Slovenia
    Amending protocol signed

    08-09-2012

    Slovenia and Switzerland have signed an emending Protocol to their Income and Capital Tax Treaty on 7 September 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% withholding tax if the recipient company holds a stake of at least 25% in the capital of the distributing company.
      • 0% withholding tax if the dividends are paid to a pension fund.
      • 15% in all other cases.

    2. Interest and royalties paid amongst associated enterprises (stakes of 25% held for at least 2 years) will no longer be subject to tax at source in future.
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