Treaty shopping and the Swiss withholding tax trap

Journal
Author
Reinarz, P.
Country
Netherlands; Switzerland
Published Date
Issue
European Taxation 2001 (Volume 41), No. 11
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In recent years there has been much discussion in Switzerland whether the Federal Tax Administration may apply the anti-abuse criteria it had developed under the Netherlands-Switzerland tax treaty to other treaty situations. A decision of the Tax Appeals Commission has brought some clarify in this respect.