Byjus 1

Byjus  2

| **Aspect**                     | **Details**                                                                 |
|---------------------------------|-----------------------------------------------------------------------------|
| **Event**                       | Switzerland suspends MFN clause in tax treaty with India.                   |
| **Effective Date**              | January 1, 2025                                                            |
| **Withholding Tax Rate Change** | Increased from 5% to 10% on dividends paid to Indian entities.              |
| **Reason for Suspension**       | 2023 Indian Supreme Court ruling on the Nestle case.                        |
| **Key Ruling**                  | MFN clause not applicable without notification from Indian government.      |
| **Previous Rate**               | 5% under MFN clause before suspension.                                      |
| **Treaty Details**              | India-Switzerland DTAA signed on August 30, 2010.                           |
| **OECD Membership Impact**      | Colombia (2018) and Lithuania (2020) joining OECD influenced tax terms.     |
| **Impact on Indian Companies**  | Higher tax liabilities for Indian companies operating in Switzerland.       |


Aspect	Details
Event	Switzerland suspends MFN clause in tax treaty with India.
Effective Date	January 1, 2025
Withholding Tax Rate Change	Increased from 5% to 10% on dividends paid to Indian entities.
Reason for Suspension	2023 Indian Supreme Court ruling on the Nestle case.
Key Ruling	MFN clause not applicable without notification from Indian government.
Previous Rate	5% under MFN clause before suspension.
Treaty Details	India-Switzerland DTAA signed on August 30, 2010.
OECD Membership Impact	Colombia (2018) and Lithuania (2020) joining OECD influenced tax terms.
Impact on Indian Companies	Higher tax liabilities for Indian companies operating in Switzerland.

Switzerland Suspends Most Favoured Nation Clause in Tax Treaty with India