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April 2018

In its decision of 28 February 2018 (A-7299/2016), the Federal Administrative Court had to deal with the eligibility for refund of the Swiss withholding tax levied on a dividend paid to an Irish group company. Of particular interest in the present case is the fact that, in addition to the direct parent company of the receiving company (which also has its registered office in Ireland), the final beneficiary shareholder and ultimate parent company – a world-leading industrial group based in Italy- falls within the scope of the EU-Swiss agreement on the taxation of savings income.

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