EYEY

Swiss Federal Supreme Court issues decision on withholding tax reclaims on derivatives and beneficial ownership

|Tax Alerts, Legislation & Policy, Na ...|Switzerland, United Kingdom
Switzerland, United Kingdom

Executive summary

In 2008, a United Kingdom (UK)-resident entity received a dividend distribution from shares it held in a Swiss entity. These shares had been acquired to hedge derivative contracts in the course of the UK-resident entity’s standard business. Under the derivative contracts, a series of payments from the UK-resident entity to its clients were agreed. Inter alia, a settlement interest…

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