The Double Taxation Relief (Taxes on Income) (Switzerland) Order 1994

Explanatory Note

(This note is not part of the Order)

The Protocol scheduled to this Order makes certain alterations to the Convention set out in the Schedule to the Double Taxation Relief (Taxes on Income) (Switzerland) Order 1978 as amended by the arrangements set out in the schedule to the Double Taxation Relief (Taxes on Income) (Switzerland) Order 1982.

The Protocol amends Articles 11 and 12 of the Convention by providing that interest or royalties arising in one State and paid to a resident of the other State shall be taxable only in the other State if that resident is the beneficial owner of the interest or royalties.

The Protocol will enter into force on the date of the later of the notifications of each country of the completion of its legislative procedures. It will take effect in the United Kingdom for any year of assessment, financial year or chargeable period beginning on or after 1st April 1995. The date of entry into force will be published in the London, Edinburgh and Belfast Gazette.