Switzerland and Finland have signed an amending protocol to their 1991 tax treaty, implementing BEPS minimum standards, including anti-abuse provisions and arbitration mechanisms. The agreement requires legislative approval in both countries before entering into force. 

RF Report

Switzerland and Finland have moved forward with updating their longstanding tax agreement, with the Swiss State Secretariat for International Finance announcing the signing of an amending protocol to their 1991 income and capital tax treaty on 28 May 2026.

This protocol implements the minimum standards for double taxation agreements.

This protocol implements the minimum standards of the BEPS project for DTAs. Specifically, the protocol of amendment contains an anti-abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused. It also supplements the provision on the mutual agreement procedure in accordance with the minimum standard and introduces the arbitration procedure.

The cantons and the business circles concerned have welcomed the conclusion of the protocol of amendment. It still has to be approved by the legislator in both countries before it can come into force.