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If there is a disagreement between the competent Swiss authority and one or more other competent authorities covered by Article 11 on the interpretation or application of this agreement, they will endeavour to resolve it by mutual agreement. They immediately communicate the results of their consultations to the Commission of the European Communities and the relevant authorities of the other Member States. With regard to interpretation issues, the Commission may participate in consultations at the request of one of the relevant authorities. 35% (exception depending on the applicability of TTT or the automatic exchange of information between the EU and Switzerland). agreement between the European Community and the Swiss Confederation providing for measures equivalent to those provided for by the Council`s 2003/48/EC Directive on the taxation of savings income in the form of interest payments known as `community`, and the SWISS CONFEDERATION, referred to as “Switzerland” or “contracting party”, THE CONCLU ACCORD OF SUIVI:Article 1st Interest payments made by a paying agent established on the territory of Switzerland to actual beneficiaries under Article 4, which are established in a Member State of the European Union, referred to as the `Member State`, are submitted, subject to the provisions of paragraph 2 and Article 2, to the amount of interest payment. The withholding rate is 15% in the first three years of the agreement, 20% for the following three years, and 35% thereafter. Interest payments on the receivables of debtors residing in Switzerland or referring to non-resident institutions established in Switzerland are excluded from the withholding tax. For the purposes of this agreement, the term “permanent establishment” has the meaning it has under the applicable double taxation agreement between Switzerland and the debtor`s state of residence. In the absence of such an agreement, the term “permanent establishment” refers to a fixed place of activity on which the activity of a debtor is carried out in whole or in part.3 However, if Switzerland lowers its upstream tax rate on interest payments made by Swiss sources to people residing in Member States by less than 35%, it receives a reserve on these interest payments. The withholding rate is the difference between the withholding rate in paragraph 1 and the new pre-tax tax rate. However, it cannot exceed the sentence set out in paragraph 1. When Switzerland reduces the scope of its advance tax law on interest payments to residents of the Member States, all interest payments which are therefore excluded from the upstream tax are subject to withholding at the rates set out in paragraph 1.4.