In a recently published decision of 16 May 2013 (2C_1086/2012, 2C_1087/2012), the Federal Supreme Court decided on a case regarding the definition of the place of effective management (tatsächliche Verwaltung) in the context of an offshore finance company.
(a) Facts. In 2002, X. Ltd. was registered as an offshore finance company in Guernsey. The equity capital of CHF 35 million was brought in by Y. Holding AG with its headquarters in the Canton of Zug. Between 2002 and 2005, X. Ltd. gran…