MLI outlook. Both States list this Convention as a Covered Tax Agreement under the Multilateral Instrument (Portugal: item lxix of Article 2(a) of Decreto do Presidente da República n.º 70/2019; Switzerland: agreement No. 10 in its position, RS 0.671.1). However, Switzerland reserved the right under Article 35(7)(a) of the MLI to delay its entry into effect until it notifies completion of its internal procedures for each treaty, and as of October 2026 Switzerland had made that notification only for its treaties with Luxembourg, Lithuania, Czechia, Iceland and Argentina, not Portugal. The MLI therefore does not yet modify this Convention. Once it takes effect, the preamble wording of Article 6(1) of the MLI (intention to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including treaty shopping) is expected to be added. Portugal notified the existing preamble under Article 6(5) but Switzerland did not, so the new wording would be included alongside the existing text rather than replacing it; the optional recital of Article 6(3) would not apply because Portugal did not choose it.
CONVENTION BETWEEN PORTUGAL AND SWITZERLAND FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
CONVENÇÃO ENTRE PORTUGAL E A SUÍÇA PARA EVITAR A DUPLA TRIBUTAÇÃO EM MATÉRIA DE IMPOSTOS SOBRE O RENDIMENTO E SOBRE O CAPITAL.
The Portuguese Government and the Swiss Federal Council, desiring to conclude a convention for the avoidance of double taxation with respect to taxes on income and on capital, have agreed as follows:
O Governo Português e o Conselho Federal Suíço, desejando concluir uma convenção para evitar a dupla tributação em matéria de impostos sobre o rendimento e sobre o capital, acordaram nas disposições seguintes:
Title and preamble as printed in Decreto n.º 716/74 (DR I série n.º 289, 12.12.1974).
We apply tax treaties to dividends, interest, royalties, salaries and gains, prepare the relief-at-source form and refund claims, and check structures against the treaty’s anti-abuse rules. A written answer and a fixed quote within one working day.
Unofficial English translation prepared by BCA Portugal for reference. The Convention was done in Portuguese and French and only those texts are authentic. The Portuguese text is reproduced from the official publication. Editorial notes are ours and are not part of the Convention.