The double tax treaties between Switzerland and Brazil as well as between Switzerland and Saudi Arabia entered into force on 16 March 2021, respectively on 1 April 2021 and will be applicable effective January 1, 2022.
The DTT between Switzerland and Brazil provides for the following maximum residual tax rates for dividends, interest, royalties and technical services:
Dividends
Interest
Royalties
Remuneration for technical services: 10%
Should Brazil conclude a new DTT with another OECD member state that provides for lower residual withholding tax rates, these will also apply to Switzerland (cf. para. 8 of the protocol to the DTT).
The DTT between Switzerland and Saudi Arabia provides for the following maximum residual tax rates for dividends, income from receivables (interest) and royalties:
Dividends
Income from receivables (interest)
Royalties
The two DTT implement several provisions of the BEPS project. They contain an abuse clause and an administrative assistance clause concerning the exchange of information upon request.