SUMMARY
According to the information provided the test may be summarized as follows
:
The information included in the present tool is intended as general guidance
and is not represented to be comprehensive or advisory in nature. Please
contact your professional tax adviser for detailed information regarding
the topic contained herein
LIMITED TREATY BENEFITS
More than 30% of the aggregate vote and value of all shares is ultimately owned by
qualified persons resident in CH
70% or less of the aggregate vote and value of all shares is ultimately owned by qualified persons and persons which are resident of an EU, EEA or NAFTA member State
Under
these circumstances limited treaty protection is not granted
|