The Double Taxation Relief (Taxes on Income) (Switzerland) Order 1978
The Convention with Switzerland scheduled to this Order replaces the Convention signed in London on 30 September 1954, as amended by the Protocol signed in London on 14 June 1966 and by the Supplementary Protocol signed in London on 2 August 1974. It provides that certain trading profits not arising through a permanent establishment, interest, royalties, pensions (other than Government pensions) and the earnings of temporary business visitors are (subject to certain conditions) to be taxed only in the country of the taxpayer's residence. Government salaries and pensions are normally to be taxed by the paying Government only. Payments made for the maintenance of visiting students are (subject to certain conditions) to be exempt in the country visited. Provision is made for income from immovable property to be taxed in the country in which the property is situated. Capital gains arising from the disposal of movable property are normally to be taxed only in the country of the taxpayer's residence unless they arise from the disposal of assets of a permanent establishment which the taxpayer has in the other country. Shipping and air transport profits are to be taxed only in the country in which the place of effective management is situated.