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 a Swiss resident trust or estate

The ultimate beneficial owners are not qualified persons in the aggregate of a predominant interest in the form of a participation or otherwise

Under these circumstances treaty protection is not granted