Federal Council adopts dispatch on double taxation agreement with Zimbabwe
Berne, 05.11.2025 — During its meeting on 5 November 2025, the Federal Council adopted the dispatch on the double taxation agreement (DTA) with Zimbabwe. The agreement will create legal certainty for the further development of bilateral economic relations and tax cooperation between the two countries.
With this DTA, Switzerland can expand its network of double taxation agreements in southern Africa. The agreement will ensure legal certainty and a contractual framework that will have a beneficial impact on the development of bilateral economic relations between the two countries.
The DTA largely corresponds to the Model Convention of the Organisation for Economic Co-operation and Development (OECD) and standard Swiss practice for agreements in this area. It will prevent the double taxation of private individuals and legal entities with an international nexus in the area of income taxes, for example in the case of the taxation of dividends, interest and royalties.
The DTA also takes account of the outcomes of the OECD's base erosion and profit shifting (BEPS) project. In particular, it provides for an anti-abuse clause that is intended to prevent a person who is resident in neither Switzerland nor Zimbabwe from claiming benefits provided for in the DTA. Moreover, the DTA contains an administrative assistance clause in accordance with the current international standard for the exchange of information upon request. Switzerland supports international efforts to achieve greater transparency and a level playing field with regard to the taxation of multinationals.
The cantons and the business associations concerned have welcomed the conclusion of this DTA. The agreement still has to be approved by Parliament before it can come into force. In Zimbabwe, the competent authority has already approved the agreement.