Société Schneider Electric Case:
French–Swiss Tax Law Analysis

French-Swiss Point of View on the Société Schneider Electric Case: Some Thoughts on the Personal Attribution of Income Requirement in International Tax Law

The publication analyses the landmark Société Schneider Electric case from a French–Swiss perspective in international tax law. It focuses on the principle of personal attribution of income and its relevance for applying double taxation treaties, particularly in conflicts between domestic tax rules and international conventions. The article highlights the broader implications of the case for cross-border taxation, emphasizing the primacy and interpretation of tax treaties in allocating taxing rights.