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SUMMARY RESIDENT PERSON PREDOMINANT INTEREST TEST The ultimate beneficial owners are not qualified persons in the aggregate of a predominant interest in the form of participation or otherwise STOCK EXCHANGE TEST The principal class of shares is not listed or is not regularly and primarly traded on one or more recognized stock exchanges The ultimate beneficial owners of a predominant interest in the company are not one or more companies which meet the direct stock exchange test 95% SHAREHOLDER TEST Less than 95% of all the shares (of the aggregate vote and value) are ultimately owned by seven or fewers persons that are qualified persons of a member state of the EU or of the EEA or a party to the NAFTA ACTIVE TRADE OR BUSINESS TEST The person is engaged in the active conduct of a trade or business in CH The income derived by this person from USA is derived in connection with the business activities carried on in CH The income is derived from a related party The trade or business of the income recipient is not substantial in relation to the income producing activity HEADQUARTER TEST The person receiving the income is a Swiss resident company and it is a recognized headquarters company for a multinational corporate group The headquarters company carries out a substantial part of the overall supervision and administration of a multinational group of companies and these activities are carried out in Switzerland The group does not consist of corporations which are residents of or are not actively engaged in business activities carried on in at least five countries or five groups of countries Under these circumstances treaty protection is not granted
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