Agreement of August 20, 2003, regarding the Limitation on Benefits Article 22 of the Income Tax Treaty between the United States and the Swiss ConfederationCompetent Authority Agreement • September 20th, 2010
Contract Type FiledSeptember 20th, 2010The Competent Authorities of the United States and the Swiss Confederation enter into the following Agreement ("Agreement") concerning the ownership requirements under paragraph 3 of Article 22 (Limitation on Benefits) and paragraph 7 (In reference to paragraph 6 of Article 22 (Limitation on Benefits)) of the Revised Memorandum of Understanding ("MOU") 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, signed on October 2, 1996 ("Treaty"). The Agreement is entered into under paragraph 3 of Article 25 (Mutual Agreement Procedure).