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United States-Switzerland: Competent authority arrangement implementing arbitration process

U.S.-Switzerland: Competent authority arrangement

IRS Announcement 2020-13—appearing in the Internal Revenue Bulletin 2020-35 (dated Monday, August 24, 2020)—includes text of a “competent authority arrangement” entered into by the competent authorities of the United States and Switzerland regarding implementation of the arbitration process under the United States-Switzerland income tax treaty and related Protocols.

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Read text of the competent authority arrangement (in Announcement 2020-13) in IRB 2020-35 [PDF 2.18 MB]

The competent authority arrangement includes definitions of terms under the mutual agreement procedure (MAP) proceedings and addresses how to request competent authority assistance.  

KPMG observation

The new document is significantly more detailed than similar arrangements published regarding the United Kingdom and Netherlands MAPs, and is more akin to the procedure laid out under the Belgium MAP in that the arrangement with Switzerland includes more detailed provisions describing the timelines for each step of the procedure and the eligibility requirements for arbitrators.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor 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 on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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