A forth protocol to amend the U.S. income tax treaty with Spain will enter into force in November, 2019.
The United States and its treaty partners have completed ratification procedures for the protocols to amend the U.S. income tax treaties with Switzerland, Luxembourg, Japan and Spain. As a result, the protocols are now in force to amend the U.S. income tax treaties with Switzerland, Luxembourg and Japan. The protocol to amend the U.S. income tax treaty with Spain will enter into force in November, 2019. The long-awaited ratification of these protocols comes approximately ten years after the protocol was signed in the case of Luxembourg and Switzerland.
Background
The United States signed protocols to amend its tax treaties with Luxembourg and Switzerland in 2009 and with Spain and Japan in 2013. The U.S. Senate approved the tax protocols with these countries in July 2019.
Switzerland protocol
The protocol to amend the income tax treaty with Switzerland entered into force on September 20, 2019 and provides for:
The protocol was signed in September 2009.
Luxembourg protocol
The protocol to amend the income tax treaty with Luxembourg entered into force on September 9, 2019 and provides for broad exchange of information between competent authorities for tax purposes. The protocol was signed in May 2009.
Japan protocol
The protocol to amend the income tax treaty with Japan entered into force on August 30, 2019 and provides for:
The protocol was signed in January 2013.
Spain protocol
The protocol to amend the income tax treaty with Spain will enter into force on November 27, 2019 and provides for:
The protocol was signed in January 2013.
For more information, contact your KPMG advisor.
Information is current to September 24, 2019. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500
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