17. Juni 2015 Pre-2008 disallowance of related-party loan interest The Supreme Tax Court has held that the pre-2008 disallowance of loan interest on related-party finance for the purchase of shares refers to direct investments only. Kategorien: Supreme Tax Court casesSchlagwörter: loan interest, related party finance, th ...
05. Januar 2011 Swiss double tax treaty excludes thin capital rule The Supreme Tax Court has held that the thin capital rules in force up to 2007 are in breach of the non-discrimination clause in the Swiss double tax treaty. Kategorien: Supreme Tax Court casesSchlagwörter: Non-discrimination, thin capital rules, ...
