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Financial Assistance in the Form of Upstream Loans in the Light of Certain Swiss Corporate and Tax Law Aspects

December 2004

Upstream loans granted by Swiss companies to their parent or affiliated companies must in each case be examined in the light of certain specific restrictions and conditions imposed by general principles of Swiss corporate and tax law. These principles do generally also apply to a Swiss company transferring its liquid funds into a central cash management or cash pooling structure of the group.

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