On 7 June 2017, Swiss representatives signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“BEPS Convention”). Once in force, the BEPS Convention will amend 14 of Switzerland’s double taxation agreements and implement, among other measures, an arbitration dispute resolution procedure. Where two contracting states are unable to reach an agreement within a certain timeframe, the affected taxpayer can initiate an arbitration procedure on any unresolved issues.
The article provides background information, gives an overview over the arbitration procedure under the BEPS Convention while highlighting potential pitfalls from a Swiss perspective.
ASA Bulletin