The Swiss Federal Tax Administration issued a statement on 11 December 2024, announcing that the application of the MFN clause under the 1994 Swiss-India tax treaty is suspended with effect 1 January 2025. As a result, dividends will be subject to a maximum withholding tax rate of 10% from 1 January 2025.
The MFN clause has been suspended following an Indian Supreme Court Ruling issued in October 2023. As previously reported, the Supreme Court concluded that when the conditions for an MFN…