The Swiss State Secretariat for International Finance has announced the signing of an amending protocol to the 2000 income and capital tax treaty with North Macedonia on 19 May 2021. The protocol is the first to amend the treaty and will enter into force after the ratification instruments are exchanged.

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Switzerland and North Macedonia sign protocol of amendment to double taxation agreement

On 19 May 2021 in Skopje, Switzerland and North Macedonia signed a protocol of amendment to the agreement for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the minimum standards for double taxation agreements.

Specifically, the protocol of amendment contains an abuse clause relating to the primary purpose of an arrangement or transaction. Moreover, a provision concerning the exchange of information upon request is included in the DTA.

The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by the legislator in both countries before it can come into force.