On 23 September 2016, the Swiss Federal Council announced a consultation on a proposed amendment to the Withholding Tax Ordinance to promote financing activities of groups in Switzerland. According to the media release, the amendment concerns groups in which a Swiss group company (guarantor) provides a guarantee for a bond of a foreign group company (issuer) belonging to the same group. With the proposed amendment, intra-group interest payments of the Swiss guarantor are no longer to be subj…