Switzerland and the U.S. Sign Competent Authority Arrangement on Dividends Withholding Exemption for Pensions and Other Retirement Arrangements

The Swiss Federal Tax Administration has published a competent authority arrangement (CCA) with the U.S. that was signed by Switzerland on 16 April 2021 and by the U.S. on 6 May 2021.

The CCA concerns the eligibility of Swiss and U.S. pension or other retirement arrangements for the dividends withholding tax exemption provided by paragraph 3 of Article 10 (Dividends) of the 1996 Swiss-U.S. tax treaty, which was amended by the 2009 protocol to expand the exemption to also cover individual re…