The Swiss Federal Council used its 5 November 2025 meeting to approve the dispatch on a new double-taxation agreement (DTA) with Zimbabwe, clearing the way for parliamentary ratification next year. The accord replaces a 2001 convention that no longer reflects the OECD’s post-BEPS standards and Switzerland’s 2019 policy on treaty abuse.
Under the new treaty, withholding tax on cross-border dividends will drop from 15 % to 5 % for corporate shareholdings of at least 10 %, and to 0 % for pension funds and the two governments. Interest and royalty withholding will be capped at 5 %. The agreement also contains an article on assistance in the collection of tax claims and a full exchange-of-information clause in line with Article 26 of the OECD Model.
![Switzerland Moves to Ratify Double-Taxation Treaty with Zimbabwe, Easing Expatriate Assignments]()
For global mobility managers, the modernised withholding limits reduce gross-up costs for Swiss companies seconding staff to Zimbabwe and vice-versa. Payroll teams will no longer need to pre-fund high withholding and apply for slow refunds, improving cash flow for short-term assignments. The mutual-agreement procedure has been expanded to three instead of two years, giving expatriates more time to resolve residence-tie disputes.
Swiss suppliers bidding on infrastructure projects in Harare say the treaty will make bid pricing more predictable. “Being able to quote a 5 % dividend rate instead of 15 % on repatriated profits immediately improves our internal rate of return,” noted the CFO of a Zürich-based engineering firm with 40 staff on rotation in Zimbabwe.
The dispatch must still pass both chambers of the Federal Assembly. If neither side calls for a referendum — considered unlikely — the DTA could enter into force on 1 January 2027, applying to salary payments from that date. Mobility teams should review current cost-projection models and update assignment policies accordingly.
Under the new treaty, withholding tax on cross-border dividends will drop from 15 % to 5 % for corporate shareholdings of at least 10 %, and to 0 % for pension funds and the two governments. Interest and royalty withholding will be capped at 5 %. The agreement also contains an article on assistance in the collection of tax claims and a full exchange-of-information clause in line with Article 26 of the OECD Model.
For global mobility managers, the modernised withholding limits reduce gross-up costs for Swiss companies seconding staff to Zimbabwe and vice-versa. Payroll teams will no longer need to pre-fund high withholding and apply for slow refunds, improving cash flow for short-term assignments. The mutual-agreement procedure has been expanded to three instead of two years, giving expatriates more time to resolve residence-tie disputes.
Swiss suppliers bidding on infrastructure projects in Harare say the treaty will make bid pricing more predictable. “Being able to quote a 5 % dividend rate instead of 15 % on repatriated profits immediately improves our internal rate of return,” noted the CFO of a Zürich-based engineering firm with 40 staff on rotation in Zimbabwe.
The dispatch must still pass both chambers of the Federal Assembly. If neither side calls for a referendum — considered unlikely — the DTA could enter into force on 1 January 2027, applying to salary payments from that date. Mobility teams should review current cost-projection models and update assignment policies accordingly.
