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Swiss Federal Supreme Court Denies Benefits Under Tax Treaty with Luxembourg in Stock Lending Transaction Case

|Treaty Development|Switzerland-Luxembourg
Switzerland-Luxembourg

According to recent reports, Switzerland's Federal Supreme Court has issued a decision concerning whether the beneficial tax treatment of dividends under the 1993 tax treaty with Luxembourg may be claimed in respect of dividends paid on Swiss shares borrowed under a Global Master Stock Lending Agreement (GMSLA).

The case involved a Luxembourg resident that borrowed Swiss shares from an affiliated UK lender under a GMSLA against cash collateral.  The GMSLA provided for the transfer …

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