On 14 June, 2024, the Swiss Federal Council announced the dispatch of the approval of a double taxation agreement (DTA) with Angola. The agreement will create legal certainty for the further development of bilateral economic relations and tax cooperation between the two countries.

With this DTA, Switzerland can expand its network of double taxation agreements in southern Africa. The agreement will ensure legal certainty and a contractual framework that should benefit the development of bilateral economic relations between the two countries.

The DTA largely corresponds to the Model Convention of the Organisation for Economic Co-operation and Development (OECD) and standard Swiss practice for agreements in this area. It will prevent the double taxation of private individuals and legal entities with an international nexus in the area of income taxes, for example, in the case of the taxation of dividends, interest, and royalties.

The DTA also takes account of the outcomes of the OECD’s base erosion and profit shifting (BEPS) project. In particular, it provides for an anti-abuse clause that is intended to prevent a person who is resident in neither Switzerland nor Angola from claiming benefits provided for in the DTA. Moreover, it contains an administrative assistance clause in accordance with the current international standard for the exchange of information upon request.

Switzerland supports international efforts to achieve greater transparency and a level playing field with regard to the taxation of multinationals. The cantons and the business associations concerned have welcomed the conclusion of this DTA.

Signed on 30 November, 2023, this tax treaty is the first between the two countries. The agreement still has to be approved by the Parliament in Switzerland and by the competent authority in Angola before it can enter into force.