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Executive summaryIn 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 payment in the amount of withholding tax(es) levied was agreed, provided certain conditions were met.The Swiss Federal Tax Administration granted a partial refund of withholding tax levied on the 2008 distribution and rejected the remainder of the reclaim.The Swiss Federal...