Notes

Mossack Fonseca, Switzerland: Double Tax Agreement with Argentina

On October 29, 2015, the Swiss State Secretariat for International Financial Matters announced that the double taxation agreement (DTA) with respect to taxes on income and capital between Switzerland and Argentina will enter into force on November 27, 2015. It replaces the agreement of 1997 and is in line with the current international standard on the exchange of information.

The purpose of the new agreement is the avoidance of double taxation with respect to taxes on income and on capital, particularly those on dividends, interest and royalty payments. It adopts the majority of the provisions of the former agreement and complies with the current international standard on the exchange of information upon request. The new agreement will be applicable from January 1, 2016, with the exception of taxes withheld at source, for which relief will already be applied in 2015 according to the agreement.

The new agreement sets the maximum withholding tax rate for dividends at 15 percent, and provides for a ten percent rate where the beneficial owner is a company that holds directly at least 25 percent of the capital of the company paying the dividends. The withholding tax rate for interest payments is capped at 12 percent. The maximum withholding tax rate for royalties is 15 percent, with reduced rates of ten, five, and three percent applicable in certain circumstances.