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 partnership

ACTIVE TRADE OR BUSINESS TEST

The person is not engaged in the active conduct of a trade or business in CH

Under these circumstances treaty protection is not granted