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Swiss Federal Supreme Court issues decision on beneficial ownership of interest on bonds linked to cross-currency swaps

|Tax Alerts, National/Federal Taxation, G ...|Switzerland
Switzerland

  • The Swiss Federal Supreme Court has held that a Danish-resident special credit institution qualified as the beneficial owner of interest income from Swiss government bonds linked to cross-currency swaps, which should in principle mean the entity was entitled to relief from withholding tax in Switzerland.
  • The case has been remanded to the lower court to decide whether the taxpayer's withholding tax …

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