OrbitaxOrbitax

Swiss Federal Supreme Court Denies Benefits Under Tax Treaty with Luxembourg in Stock Lending Transaction Case

|Treaty Development|Switzerland-Luxembourg
Switzerland-Luxembourg

According to recent reports, Switzerland's Federal Supreme Court has issued a decision concerning whether the beneficial tax treatment of dividends under the 1993 tax treaty with Luxembourg may be claimed in respect of dividends paid on Swiss shares borrowed under a Global Master Stock Lending Agreement (GMSLA).

The case involved a Luxembourg resident that borrowed Swiss shares from an affilia…

Continue Reading