Switzerland signs with Malta and Singapore

28 February 2011

Switzerland has signed double taxation treaties with Malta and Singapore.

As well as provisions on withholding taxes, both treaties incorporate the wide-ranging tax information exchange provisions published by the Swiss earlier this month.

These provisions allow the foreign country’s tax authorities to demand information on a suspected individual’s bank accounts even if they do not know the name of his bank, or even his own name.

The Singapore treaty sets a 5 per cent withholding tax on cross-border dividend payments to non-portfolio shareholders (those holding at least 10 per cent of a company). Interest payments will also be subject to the 5 per cent levy.

The Malta treaty exempts non-portfolio shareholders from withholding taxes on all cross-border dividend or interest payments. However, this is subject to two conditions: first that the shareholding is held for a year or more, and second that it is not an “artificially arranged” device. 

It is not certain when the treaties will come into force, but 1 January 2012 is a likely bet.


Swiss Federal Ministry of Finance (Malta treaty)

Swiss Federal Ministry of Finance (Singapore treaty)



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