The Swiss action came after India's Supreme Court rejected automatic applicability of the MFN clause under the bilateral tax treaty in a case related to Swiss firm Nestle.In its December 11 order, the Swiss government said the SC's ruling shows Switzerland's interpretation of the MFN clause under the Double Taxation Avoidance Agreement is not shared by the Indian side. Therefore, it said it was waiving its unilateral application of the MFN clause with effect from January 1, 2025.Accordingly, income accruing on or after January 1, 2025 may be taxed in Switzerland at higher rates. The applicable residual rates on dividends paid by Indian firms in Switzerland would be 10% instead of 5% under the MFN clause.The MFN clause provides for lowering the rate of taxation at source on dividends, interest, royalties, or fees for technical services similar to concessions given to other countries."Switzerland's move underscores the growing emphasis on reciprocity and mutual agreement in the interpretation of treaty provisions," said Sandeep Jhunjhunwala, M&A tax partner, Nangia Andersen.

Switzerland withdraws MFN status for India

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is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 88 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.

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{{magzter}} is the World's largest and fastest growing self-service, cross-platform digital newsstand with over 88 million users since its inception in 2011 and thousands of magazines and newspapers across 40+ categories and 60+ languages. Headquartered in New York, Magzter has its local presence in Amsterdam, London, Mexico City, Chennai, Mumbai, New Delhi, Bengaluru, Singapore, and will soon be expanding to other countries. Founded by global entrepreneurs, Girish Ramdas and Vijay Radhakrishnan in June 2011, Magzter enables magazine and newspaper publishers around the world to create and deliver digital editions of their titles to global consumers.