Switzerland: Treaty shopping and the Swiss withholding tax trap
P. Reinarz
Abstract
P. Reinarz
Abstract
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.
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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.
Key concepts: Tax treaty, Treaty, Commission, Political science, Trap (plumbing), Business, Double taxation, International trade