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Switzerland suspends MFN status to India following tax ruling changes
Switzerland has suspended the unilateral application of the most favoured nation (MFN) clause with India under the Double Tax Avoidance Agreement, reverting the withholding tax on Indian entities from 5% back to 10% effective January 1, 2025. This decision follows a Supreme Court ruling that affected the application of the MFN clause, highlighting the lack of reciprocity from India. Consequently, while Indian companies in Switzerland will still benefit from other DTAA provisions, dividends paid to Indian holding companies will now be taxed at the higher rate.
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