OrbitaxFederal Tax Authorities: Interaction between Anti-abuse Decree and specific treaty provisions clarified
|Treaty Development|Switzerland
The Federal Tax Authorities has recently clarified the relationship between anti-abuse provisions in tax treaties and the Federal Council's Decree on measures against the improper use of tax treaties ("Anti-abuse Decree"). Anti-abuse provisions in tax treaties supersede the Anti-abuse Decree. However, the Anti-abuse Decree still applies if a treaty:
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