U.S.-Switzerland Competent Authority Arrangement

On March 21, the IRS released (Announcement 2025-8) a copy of the Competent Authority Arrangement (CAA) between the United States and Switzerland regarding certain U.S. and Swiss pension or other retirement arrangements, including individual retirement savings plans, that may be eligible for treaty benefits.

The arrangement, entered under Article 25, paragraph 3, of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income signed at Washington on Oct. 2, 1996, as amended by the Protocol signed on Sept. 23, 2009 (the “treaty”), addresses the eligibility of U.S. and Swiss pension or retirement plans for benefits under Article 10 (Dividends) of the Treaty.

The arrangement was signed Dec. 5, 2024, becomes operative for dividends paid on or after Jan. 1, 2020, and supersedes the CAA entered into on May 6, 2021.