Trends and Developments in Swiss Anti-Treaty Shopping Legislation and Treaty Shopping Case Law

Journal
Jung, M.R.
Switzerland
European Taxation 2011 (Volume 51), No. 6
FormatPDF
EUR
40
| USD
45 (VAT excl.)

The author highlights the trends and developments in Swiss anti-treaty shopping legislation and treaty shopping case law. He exposes the standard cases of improper use of tax treaties from a Swiss withholding tax perspective. He further analyses the relationship between unilateral anti-avoidance measures and treaty law and explores the scope and limits of the unilateral judicial tax avoidance and abuse of rights doctrines. He then analyses the recent case law of the Federal Tribunal and the Federal Administrative Court.