Tax on distributed profits

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On 6 May 2025, the Swiss Federal Court ruled in the decision 9C_630/2024 on a central issue: the reassessment of a company's tax liability following a tax audit which revealed undue benefits granted…

In international customary law, the scope of bilateral tax conventions is not exhaustive and instead limited by the temporal scope set out in ‘taxes covered’ clause. It is true that the scope of such…