Croatia and Switzerland’s protocol amending their 1999 income and capital tax treaty entered into force on 16 October 2026, introducing OECD minimum standards and changes to business profits, associated enterprises and exchange of information provisions.
Croatia and Switzerland’s amending protocol to their 1999 income and capital tax treaty entered into force on 16 October 2026.
Signed on 18 July 2025, the protocol implements OECD’s minimum standards for double taxation agreements (DTA). In particular, the protocol of amendment contains an abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused.
It also contains an administrative assistance clause in accordance with the international standard for the exchange of information upon request.
It will take effect once both countries exchange their instruments of ratification, with its provisions generally applying from 1 January of the following year.
Earlier, the Swiss Council of States approved the ratification of the amending protocol to the 1999 income and capital tax treaty with Croatia on 9 March 2026.
