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Significant Swiss WHT improvements for international debt financings

February 2019

The Swiss Federal Tax Administration has announced on 5 February 2019 a new practice that significantly improves the ability of corporate groups to raise debt abroad and to use such debt in Switzerland.

It is now possible to raise debt abroad and to "flow back" such funds to Switzerland in an amount aggregate to the equity of all non-Swiss subsidiaries (equity exception) and all intragroup funding granted to non-Swiss group members (intragroup funding exception).

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