The Swiss Federal Tax Administration has published a mutual agreement signed with the UK on 16 June 2021 regarding the implementation of paragraph 5 of Article 24 of the 1977 Swiss-UK tax treaty. Paragraph 5 contains arbitration provisions for cases that have not been resolved within three years of a case being presented. The agreement covers arbitration requests, selection and appointment of arbitrators, the arbitration process, and other matters for arbitration.
The mutual agreement is generally effective from 15 December 2013, which is the date paragraph 5 of Article 24 became effective.