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


The person receiving the income is neither :

  • a Swiss resident company
  • a Swiss resident partnership
  • the Swiss State, a political subdivision or local authority thereof, or an agency of instrumentality of the Swiss State, political subdivision of authority
  • a Swiss resident individual
  • a Swiss resident trust or estate
  • a Swiss resident family foundation
  • a Swiss resident pension trust or a not-for-profit organisation

Under these circumstances treaty protection is not granted