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  • Swiss Confederation MOU on tax treaty arbitration

    A memorandum of understanding (MOU) with the Swiss Confederation on the arbitration process for unresolved issues under the mutual agreement procedure (MAP) has been finalised.

    Subject to certain conditions, independent and binding arbitration is available under the Australia-Switzerland tax treaty for issues arising from a MAP case that remain unresolved after three years.

    The MOU with the Swiss Confederation can be accessed via the ATO Legal Database and the arbitration section of the MAP content on our website.

    Under article 24 of the tax treaty, the competent authorities of Australia and the Swiss Confederation are required to bilaterally conclude a MOU to settle the mode of application of MAP arbitration. The MOU reflects the mutual understanding between the competent authorities of Australia and Switzerland on the procedural and operational details of the arbitration process.

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    Last modified: 07 Oct 2020QC 63867