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.