The Offshore Financing of Swiss Groups: A Recent Decision of the Swiss Federal Court Regarding Outbound Permanent Establishments
Journal
International; Switzerland
Bulletin for International Taxation 2013 (Volume 67), No. 7
In a recent decision, the Swiss Federal Supreme Court considered the activities performed by the taxpayer to be insufficient to justify an offshore permanent establishment for financing purposes in respect of a purely Swiss group that exercised its core business activities exclusively within Switzerland.