Swiss Federal Supreme Court issues decision on beneficial ownership of interest on bonds linked to cross-currency swaps
|Tax Alerts, National/Federal Taxation, G ...|Switzerland
The Swiss Federal Supreme Court has held that a Danish-resident special credit institution qualified as the beneficial owner of interest income from Swiss government bonds linked to cross-currency swaps, which should in principle mean the entity was entitled to relief from withholding tax in Switzerland.
The case has been remanded to the lower court to decide whether the taxpayer's withholding tax refund request must be denied as contrary to the Switzerland-Denmark double tax treaty.
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