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Switzerland has recently witnessed an unprecedented amount of tax treaty negotiations. Although this is a direct result of Switzerland’s revised position regarding exchange of information, a number of Contracting States have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are developed extensively in this fourth revised edition.
As Switzerland has steadily aligned itself with the principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have been modified significantly. Indeed, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations.
Switzerland in International Tax Law is designed for practitioners wishing to acquire a working knowledge of the Swiss tax issues involved in international cross-border investment. Whether Switzerland is the source or the destination of income, both domestic and international laws are explained in detail.
Due to Switzerland’s traditional role in international taxation, particular attention has been paid to the special tax relief granted to Swiss resident individuals and corporations as well as the complex rules for the avoidance of treaty abuse.