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Swiss Court Holds Beneficial Ownership Must be Determined based on the Entire Economic Context

|Treaty Development|Switzerland-Denmark
Switzerland-Denmark

The Swiss Federal Supreme Court recently published its May 2015 decision regarding beneficial ownership under the Denmark-Swiss tax treaty in a case involving total return swaps and dividend payments. The main question was whether a Danish bank that entered into swap contracts with clients in England, Germany, France and the U.S. was entitled to the beneficial withholding tax treatment on related dividends under the Denmark-Swiss tax treaty.

In an agreement entered into between the bank and …

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