The Swiss Federal Tax Administration has published a mutual agreement signed with the UK on 16 June 2021 regarding the implementation of paragraph 5 of Article 24 of the 1977 Swiss-UK tax treaty. Paragraph 5 contains arbitration provisions for cases that have not been resolved within three years of a case being presented. The agreement covers arbitration requests, selection and appointment of arbitrators, the arbitration process, and other matters for arbitration.
The mutual agreement is ge…