Treaty detail
United Kingdom - Switzerland tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1977-12-08
Effective
1978-09-07
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The treaty as amended provides a 0 percent rate for qualifying corporate shareholders meeting the substantial-direct-ownership threshold under the article. The 15 percent rate applies otherwise.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest.
Royalties
Rate: 0%
The treaty eliminates source-country royalty withholding across the major categories under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis has been updated by protocol to reflect modernized OECD model wording.
Other treaty flags
Pension treatment is article-specific. The treaty addresses Swiss occupational and cantonal pension arrangements alongside UK pension scheme treatment.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the original 1977 wording as amended by protocol.
Article 4 has been amended several times. The 2017 protocol added BEPS-era anti-abuse provisions, including a principal-purpose-test consistent with MLI standards.
Article 5
Permanent Establishment
Sets the business-presence threshold with a 12-month construction rule.
The treaty uses the standard 12-month construction threshold as amended by protocol.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 has been refined by protocol to align more closely with the OECD authorised-approach to profit attribution.
Article 10
Dividends
Caps source-country dividend withholding, with a zero rate for qualifying substantial shareholders.
Article 10 produces a 0 percent rate for qualifying corporate shareholders meeting the substantial-direct-ownership threshold under the article as amended. Portfolio dividends face the 15 percent ceiling.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding. The 2009 protocol added enhanced information-exchange provisions affecting how the article is applied in practice.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding under the article as amended by protocol.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CH treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
Primary sources
- HMRC: Switzerland tax treatiesVerified 2026-05-20
- Swiss Federal Tax Administration treaty pageVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.