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 engaged in the active conduct of a trade
or business in CH
The income derived by this person from USA is not
derived in connection with the business activities carried on in CH
The income derived from USA is not incidental to the
trade or business in CH
Under
these circumstances treaty protection is not granted
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