| 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
 
 LIMITED TREATY BENEFITS
 30% or less of the aggregate vote and value of all shares is ultimately owned by 
        qualified persons resident in CH
 Under 
        these circumstances limited treaty protection is not granted
  
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