25 August 2025 | Publication
IFA 2025 - Subject 2 - Branch Report for
Switzerland - Subject B: Improper use of
tax treaties and source taxation:
policy, practice and beyond
25 August 2025 | Publication
IFA 2025 - Subject 2 - Branch Report for
Switzerland - Subject B: Improper use of
tax treaties and source taxation:
policy, practice and beyond
cahiers de droit fiscale international, vol. 109/2025, IFA Lisbon Congress 2025 Journal
This publication provides an in-depth analysis of Switzerland’s approach to tax treaty abuse and source taxation, focusing on anti-abuse measures, withholding tax (WHT) practices, and the interaction between domestic and international tax law. Key topics include the Swiss Federal Tax Administration’s criteria for identifying treaty abuse, the application of general and specific anti-avoidance rules (GAAR and SAAR), and the impact of the OECD’s BEPS project and Multilateral Instrument (MLI) on Swiss tax policy.
This publication provides an in-depth analysis of Switzerland’s approach to tax treaty abuse and source taxation, focusing on anti-abuse measures, withholding tax (WHT) practices, and the interaction between domestic and international tax law. Key topics include the Swiss Federal Tax Administration’s criteria for identifying treaty abuse, the application of general and specific anti-avoidance rules (GAAR and SAAR), and the impact of the OECD’s BEPS project and Multilateral Instrument (MLI) on Swiss tax policy.
