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Double Taxation Agreement Ireland Switzerland

Since our negotiations with the Netherlands were so advanced before the end of the OECD`s work, it was felt that it would be quicker to conclude the agreement by ratifying the OECD amendments in the agreement, while the work with the Swiss authorities took place later. That is why we believe that the best way to move it forward is to have a protocol. I am not asking for such a change. I wonder about our existing law, because it does not apply to all other agreements. If a company transferred or changed its residence from here to another country, for example. B Luxembourg, it would not benefit—– from Swiss income tax and property taxes levied in countries with which Switzerland has not concluded a DTT, nor are the underlying income or assets exempt from Swiss tax. However, the taxpayer may claim a deduction of input VAT equal to uncollectible foreign taxes. The Committee will recall that last year Ireland ratified the Multilateral Agreement on the Implementation of Measures Relating to the Tax Convention to Prevent Profit Reduction and Profit Shifting (BASE Erosion and Profit Shifting). The Convention was discussed in this committee and in Dáil Eireann and incorporated into the 2018 Finance Law.

The multilateral BEPS convention updates most of Ireland`s existing double taxation treaties. However, as announced to the committee last year, our existing double taxation treaties with the Netherlands and Switzerland have not been updated by the agreement, but rather updated bilaterally to reflect the beps changes. That is what these two agreements, which are now before the committee, are trying to achieve. I am pleased to be here to present to the committee two draft government ordinances which bring into force in Ireland a new substitution double taxation agreement with the Netherlands and a new protocol to the existing double taxation agreement with Switzerland. The new double taxation agreement with the Netherlands was signed on 13 June 2019, on behalf of Ireland, by the Minister of State, Deputy O`Donovan, on behalf of Ireland and the Minister for Foreign Affairs, Stef Blok, on behalf of the Netherlands, in the context of Her Majesties` State visit to Ireland, of the King and Queen of the Netherlands. The protocol to the double taxation agreement with Switzerland was also signed on 13 June 2019 by Deputy D`Arcy and the Swiss Ambassador to Ireland. The protocol became necessary to appease the European Commission, which considered that the agreement could be contrary to the European treaty. Threatened by a possible challenge before the Court of Justice of the European Communities, Britain and Switzerland have agreed that account holders who have already paid the 35% withholding tax due under the EU Savings Tax Directive will be subject to a final withholding tax of 13% to honour the tax debt on interest payments. . . .


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