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

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 relat…
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