The Netherlands and Switzerland have amended their tax treaty in a protocol. New agreements have been made against tax avoidance, as well as with regard to the taxation rights on pensions.
An anti-abuse clause has been included that prevents the benefits of the treaty from being used solely to avoid taxation.
In addition to some other changes, the main adjustment further relates to the allocation of the taxing rights between the Netherlands and Switzerland regarding pensions. This taxing right has until now been allocated to the source state, provided that various conditions are met. These conditions will lapse and the taxing right will be limited to a maximum of 15 percent.