Treaty relief in Switzerland on outbound investment

Journal
Hull, H.R.; Teuscher, H.
Bulletin for International Taxation 2001 (Volume 55), No. 2
PriceUSD 45

This article considers the Swiss domestic anti-abuse rules which apply when a Swiss resident claims relief from foreign withholding tax on the basis of a treaty. The analysis is in light of the new guidelines issued by the Swiss Federal Tax Administration which relax the conditions for Swiss resident companies for obtaining treaty relief on foreign-source income.