The EC Parent-Subsidiary Directive in Switzerland - Swiss outbound dividends

The agreement between the Swiss Confederation and the European Community on the taxation of savings (Swiss-EU Agreement) includes a provision (Art. 15) which grants Switzerland measures equivalent to those found in the EC Parent-Subsidiary Directive of 1990. For the reasons explained in the article, Swiss outbound dividends will benefit from the relief provided in the Swiss-EU Agreement. This article examines the taxation of dividends paid by Swiss subsidiaries to EU parent companies. The article considers the principles of domestic legislation, international tax treaties, the Swiss-EU Agreement and the Parent-Subsidiary Directive. The Appendix shows the conditions for the withholding tax relief in Switzerland under the Swiss-EU Agreement.