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Switzerland - Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares

Country:
Switzerland
Author:
P. Reinarz
Issue:
Derivatives & Financial Instruments, 2017 (Volume 19), No 3
Published:
12 June 2017
The Swiss Federal Administrative Court upheld a decision by the Federal Tax Administration to reject the tax treaty-based partial refund claims of a Luxembourg resident financial institution for Swiss withholding tax on dividends paid on stock exchange-listed Swiss shares, which Lux Bank had borrowed from an affiliated financial institution resident in the United Kingdom.
 
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