3. A company residing in Switzerland and reaping dividends from a company domiciled in Australia is entitled, for taxation purposes in Switzerland, to the same exemption that would be granted to the company if the number of dividends of the company were established in Switzerland. 1.45 The term “taxable as a resident” is used to cover persons subject to general taxation under a country`s national tax law. A person may be considered taxable, even if the country does not tax that person`s income. 1.288 Referral to a competent authority must be submitted within three years of the first notification of the appeal, which, in the person`s view, is not formulated in accordance with the Swiss convention. The presentation of a case does not deprive the individual of access to other remedies, which are available under the national legislation of both countries, or to infringe his rights against them. [Article 24, paragraph 1] 1.265 This article ensures that, in the same circumstances, nationals of one country are not treated less favourably than nationals of the other country. This principle applies to taxation itself as well as to all tax requirements. As a result, discrimination in the administration of a country`s tax legislation is generally excluded.
[Article 23, paragraph 1] In October 2010, an agreement was signed to begin negotiations for an agreement to tax unreported British accounts in Switzerland and other information regarding tax and banking information shared between the two states. The agreement will strengthen, among other things, cross-border tax cooperation and improve banks` access to the market. Negotiations began in early 2011 and the agreement was signed on 6 October 2011. On March 20, 2012, a protocol was signed to clarify outstanding issues. For royalties, the tax limit for source countries is 5%. The definition of “royalties” excludes any payment or credit for the use or right to use commercial, commercial or scientific equipment. [Article 12, paragraphs 2 and 3] – other amounts subject to the same tax treatment as the income from the shares of the country in which the distribution company is established for the purpose of its tax.