DTA Abuse

Note: The Swiss Federal Council has repealed the Ordinance on Measures against the unjustified use of Federal Double Taxation Agreements ("BRB 62") as of 01.01.2022.

DTA abuse refers to cases where tax relief is claimed in an abusive or unlawful manner based on double taxation agreements. Switzerland has taken measures to counter this. The Federal Tax Administration circulars dated 31 December 1962, 17 December 1998 and 1 July 2010 contain detailed explanations. More information on DTA abuse can be found on the website of the State Secretariat for International Finance SIF.

Questions & answers to the DTA abuse

Frequently asked questions (FAQ) concerning the application of Swiss anti-abuse provisions to payments of dividends, interest and royalties from the EU to associated corporations in Switzerland (Article 15 of the Agreement on the Taxation of Savings).

Further information

Last modification 04.04.2022

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