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 company

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

The principal class of shares is not listed and is not regularly and primarly traded on one or more recognized stock exchange

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

95% or more 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

More than 50% of the gross income is used to make deductible payments to persons which are neither qualified persons nor US citizens

ACTIVE TRADE OR BUSINESS TEST

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

HEADQUARTER TEST

The person receiving the income is not a Swiss resident company and it is not a recognized headquarters company for a multinational corporate group

Under these circumstances treaty protection is not granted