Buchdetails

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.