Finland and Switzerland will amend their tax treaty to introduce anti-abuse and arbitration provisions and allow Finland to tax voluntary and supplementary pensions.
Finland’s government submitted a bill to Parliament seeking approval of the amending protocol to the Finland–Switzerland Income and Capital Tax Treaty (1991) on 10 September 2026.
The protocol, signed on 28 May 2026, would amend the treaty as previously modified by protocols concluded in 2006, 2009 and 2012.
The changes mainly follow OECD minimum standards under the Base Erosion and Profit Shifting project. They include rules to deny treaty benefits in cases of abuse and introduce arbitration for mutual agreement procedures. The protocol will also allow Finland to tax voluntary and supplementary pensions paid to recipients, regardless of their citizenship or tax status. Finland will use the treaty’s existing rules to prevent double taxation.
The protocol will take effect 30 days after both countries confirm that they have completed their domestic approval procedures.
