Switzerland, Latvia Revise Tax Treaty To Tackle BEPS

On June 28, 2017, the Swiss Federal Council adopted the dispatch on a revised double taxation agreement with Latvia and submitted it to Parliament for approval.

A protocol to revise the agreement was signed by the two countries in November 2016.

The revised agreement contains an anti-abuse clause in line with the wording of the OECD’s base erosion and profit shifting recommendations to deny treaty benefits in inappropriate circumstances. The revised treaty also incorporates an arbitration clause to increase legal certainty for taxpayers.

The revised agreement introduces lower taxation of levies and distributed profits on qualified participations.

The agreement has also been revised to introduce an administrative assistance clause allowing information to be exchanged between the two countries on request, into line with current international standards.