Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares

Journal
Switzerland
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2017 (Volume 19), No. 3
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.