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 affiliated UK lender under a GMSLA against cash collateral.  The GMSLA provided for the transfer of the legal title of the shares from the UK lender to the Luxembourg borrower, with the borrower obliged to make manufactured payments to the UK lender...