Switzerland Approves Changes for Intra-Group Interest Exemption

The Swiss Federal Council has announced its approval of an amendment to the Withholding Tax Ordinance to strengthen the financing activities of groups in Switzerland. The amendment concerns groups in which a Swiss group company (guarantor) provides a guarantee for a bond of a foreign group company (issuer) belonging to the same group. The amendment provides that interest on funds forwarded from a foreign issuer to a group company established in Switzerland will not be subject to withholding …