| 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
 
 RESIDENT PERSON
 The person receiving the income is a Swiss resident individual
 Under 
        these circumstances treaty protection is granted
  
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