Atypical silent partnerships

In its ruling 2C_333/2007, the Federal Supreme Court ruled on the refund of withholding tax to a domestic permanent establishment of a foreign company, thereby confirming the administrative practice. These considerations also have implications for atypical silent partnerships with regard to the concept of permanent establishment. The Federal Tax Administration (FTA) has drafted a statement in consultation with the Corporate Tax Working Group of the Swiss Tax Conference (SSK), setting out the current practice regarding the tax treatment of atypical silent partnerships:

As English is not one of Switzerland's official languages, only the most important information is translated into English. Please refer to the German, French or Italian original version.