On December 28, 2011 the exchange of notes regarding the ratification of the Double Tax Treaty (DTT) signed between Switzerland and Uruguay was concluded. Therefore, its tax provisions will be applicable from January 1, 2012.
The DTT is based on the OECD Model Tax Convention. However, there are some differences, such as, the inclusion of article 14 of the United Nations Model Tax Convention regarding Independent Professional Services and the old concept of “fixed base”.
