According to an update of 20 May 2021, published by the Swiss Federal Tax Administration, Switzerland and the United States have signed a competent authority arrangement (2021) regarding certain American and Swiss pensions or other retirement arrangements, including individual retirement savings plans, that may be eligible for benefits under paragraph 3 of article 10 (Dividends) of the Switzerland - United States Income Tax Treaty (1996), as amended by the 2009 protocol. The arrangement was signed by Switzerland on 16 April 2021 and by the United States on 6 May 2021.
The mutual arrangement is entered into under paragraph 3 of article 25 (Mutual Agreement Procedure) of the treaty and supersedes the competent authority arrangement of 10 December 2004, I.R.B. 2004-146. It is effective for dividends paid on or after 1 January 2020.