On 23 October 2019, the Swiss Federal Council adopted the dispatch on the protocol of amendment to the agreement with Iran for the avoidance of double taxation with respect to taxes on income and capital (DTA). The protocol implements the minimum standards for double taxation agreements.
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. Moreover, the DTA now contains a provision on the exchange of information upon request.
