The U.S. IRS has published the Implementing Arrangement Regarding Paragraphs 6 and 7 of Article 25 of the Convention between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income.
The agreement was signed by the Swiss and U.S. competent authorities on 28 July and 30 July 2020, respectively, and provides for the implementation of the arbitration process provided for in Article 25 (Mutual Agreement Procedure) of the 1996 …