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Swiss Tribunal Sides With Taxpayer in Beneficial Ownership Case

March 2012 - Tax & Private Client. Legal Developments by Walder Wyss Ltd.

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by Marcus Desax and Martin Busenhart

In what appears to be the first reported court case worldwide dealing with beneficial ownership as it applies to total return swaps in a tax treaty context, the Swiss Federal Administrative Tribunal has handed down a judgment in favor of the taxpayer. 


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