The U.S. IRS has published a new Competent Authority Arrangement (CAA) signed with Switzerland on 5 December 2024. The CAA concerns certain U.S. and Swiss pension or other retirement arrangements, including individual retirement savings plans, which may be eligible for benefits under paragraph 3 of Article 10 (Dividends) of the 1996 U.S.- Swiss tax treaty.
Paragraph 3 of Article 10 provides that dividends may not be taxed in the Contracting State of which the company paying the dividends is…