On July 17, 2019, the American Senate approved the long-blocked
protocol of amendment of September 23, 2009, on the double taxation
agreement between Switzerland and the U.S. (DTA U.S.). The main
object of the protocol is to include a provision on the exchange of
information in accordance with the OECD standard. The Swiss Federal
Assembly approved the protocol already on June 18, 2010. It will
enter into force with the exchange of the instruments of
ratification.
In addition to the agreement on the protocol of amendment, it
was also agreed at that time to start further negotiations on a
general revision of the DTAs. In this way, improvements such as the
reduction of the withholding tax on dividends from qualifying
investments to 0% (so-called zero rate") were to be achieved.
It can be concluded that the ratification of the protocol of
amendment will now allow these outstanding renegotiations to begin.
In relation to the U.S., besides the DTA provision on the
