On 9 and 10 December 1999, negotiations for a revision of the Austro-Swiss Double Taxation Convention took place in Berne. As a result a protocol to the Convention had been initialled according to which the 5% source tax on intercompany dividends shall be removed provided that the shareholder's participation amounts to at least 20%. Likewise the current 5% source taxation right on interest payments shall be cut down to zero. Such a removal of source taxation on intercompany dividends and on interest payments shall, however, be balanced by an increase of the source tax on other dividends from 5% to 15%. Whereas the zero rate on intercompany dividends shall be introduced retroactively by 1 January 2000, the other changes shall become effective only at the beginning of the year following the entry into force of the protocol, which, in turn, shall take place one month after the exchange of instruments of ratification. On the occasion of the treaty negotiations also many issues of treaty interpretation including several rulings rendered by the Austrian Ministry of Finance in the frame of its EAS-taxpayer service had been discussed and could be resolved by mutual agreement.