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Withholding Tax-Free Interest Payments by Swiss Group Companies

March 2013

Under Swiss tax law, interest payments by Swiss group companies on intra-group loans in principle are not subject Swiss withholding tax. This newsletter outlines how Swiss subsidiaries can ensure that their interest payments to group companies remain free of the 35% Swiss withholding tax and, in particular, ensure that such payments are not considered taxable due to requalification into dividend payments or payments as part of a bond-like financing or payments on customer deposits.

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