Tax treatment of intra-group cross-border interest payments involving Switzerland

Journal
Hull, H.R.
European Union; Switzerland
Bulletin for International Taxation 2007 (Volume 61), No. 8
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article focuses on the withholding tax on interest paid by Swiss companies to related companies residing abroad and vice versa. The article discusses the possibilities of qualifying for relief from the withholding tax by drawing on the principles of domestic legislation, international tax treaties, the Swiss-EU Agreement as well as the EC Interest and Royalties Directive.