Switzerland - Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares
- P. Reinarz
- Derivatives & Financial Instruments, 2017 (Volume 19), No 3
- 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.