Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares

Journal
Author
Reinarz, P.
Country
Switzerland
Published Date
Issue
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2017 (Volume 19), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

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.