New DTT with Brazil and Saudi Arabia

The new double tax treaties (DTT) are the first treaties for the avoidance of international double taxation between Switzerland and the two contracting states. The DTTs will be applicable as of January 1, 2022.


DTT with Brazil

The DTT between Switzerland and Brazil provides for the following maximum residual tax rates for dividends, interest, royalties and technical services:


  • 15% portfolio rate
  • 10% for qualified participation (minimum participation rate of 10% and minimum holding period of 365 days)
  • 0% for dividend payments to pension funds or national bank


  • 15% in principle
  • 10% resp. 0% as far as certain conditions are met


  • 15% in connection with income from a trademark
  • 10% in the other cases

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).


DTT with Saudi Arabia

The DTT between Switzerland and Saudi Arabia provides for the following maximum residual tax rates for dividends, income from receivables (interest) and royalties:


  • 15% portfolio rate
  • 5% in case of qualified participation (minimum 10% participation rate)
  • 5% if the beneficial owner is the central bank, a pension fund, a sovereign wealth fund or another government-owned entity

Income from receivables (interest)

  • 5% in principle
  • 0% if certain conditions are met


  • 5% in connection with the use of industrial, commercial or scientific equipment
  • 7% in other cases


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.

April 2021| Authors: Andreas Müller, Christina Stocker, Rosanna J. Fravi

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