The withholding tax implies an approach of the anti-abuse rules made for concrete types of income obtained from investments in the DDT and deals that the U.S. has sealed with other countries.
Taxation on capital gains applies to the rules formed by the OECD model. Gains on the property are subject to taxation in the state in which the corresponding property is located. Meanwhile, the gains from the sale of personal property are subject to taxation in the country of residence of the seller. In the case, if capital gains obtained in one contracting country are relating to a permanent establishment in the other country, they are subjected to taxation in the country in which the establishment is located.
Switzerland has over 80 DTT with countries from all around the world. Before opening a legal entity in Switzerland or making any other type of investments, it is important to consult the special provisions of the acceptable tax treaty in order.
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