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5.5. Source Rules with Respect to Income Derived by Non-Residents

Interest – Interest is generally Swiss source income if the payor is a Swiss person, Swiss bank or governmental authority.

Dividends – Dividends are generally Swiss source income if the payor is a domestic corporation.

Royalties – Royalties are Swiss source income if the IP generating the income is owned by a Swiss person.

Rents – Rents are Swiss source income if the property generating the income is located in Switzerland. This includes rental or lease income from real property even if both the payor and payee are located outside Switzerland.

Tangible Property – Income from the sale of tangible property (expect for real property) is Swiss source income if the tangible property is owned by a Swiss person. Income from the sale of real property is Swiss source income if the real property is located in Switzerland.