Protocol Amending Tax Convention with Switzerland will Enter into Force

1. On October 31, mutual notifications necessary for the entry into force of the “Protocol Amending the Convention between Japan and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income” (signed on July 16, 2021) were completed between the Government of Japan and the Government of Swiss Federal Council.

2. This Protocol, accordingly, will enter into force on November 30, 2022 (the thirtieth day after the date of completion of the mutual notifications) and will have effect:

(a) in Japan:

(i) with respect to taxes levied on the basis of a taxable year, for taxes for any taxable years beginning on or after January 1, 2023;

(ii) with respect to taxes levied not on the basis of a taxable year, for taxes levied on or after January 1, 2023;

(b) in the Swiss Confederation:

(i) with respect to taxes withheld at source, on amounts paid or credited on or after January 1, 2023;

(ii) with respect to other taxes, for taxable years beginning on or after January 1, 2023.

The provisions of paragraph 1 of Article 25 of the Convention (Mutual Agreement Procedure), as amended by this Protocol, will have effect from November 30, 2022, without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.

The provisions concerning the arbitration proceedings will have effect from November 30, 2022 with respect to:

(a) cases that are under consideration by the competent authorities of the Contracting States on November 30, 2022. For such cases, no unresolved issues arising therefrom will be submitted to arbitration earlier than three years after November 30, 2022;

(b) cases that come under consideration by the competent authorities of the Contracting States after November 30, 2022.

【Reference】 Texts and Outline of the Protocol

・“Protocol Amending the Convention between Japan and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income”（Japanese(PDF:260KB)・English(PDF:163KB)）

・“Exchanged Notes concerning the Protocol Amending the Convention between Japan and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income”（Japanese(PDF:57KB)・English(PDF:81KB)）

・Outline of the Convention

　→ Protocol Amending Tax Convention with Switzerland was Signed (July 16, 2021)