PLEASE NOTE: THIS ARTICLE WAS ORIGINALLY SUBMITTED BY REVISUISSE PRICE WATERHOUSE, SWITZERLAND
Zurich, March 5, 1998
SUMMARY
The Memorandum of Understanding was revised. The most important revisions relate to the limitation of benefits clause. They are: (1) the stock exchange test now requires that the listed company is resident in either Switzerland or the U.S., and (2) the Swiss and the U.S. Tax Authorities agreed to abolish the local ownership requirement regarding the derivative benefits test.
For a general overview of the contents of the new Swiss-U.S. income tax treaty see our article published in January 1998
The content of this article is intended to provide a general guideline to the subject matter. Specialist advice should be sought about your specific circumstances.
Your contacts for US-Swiss crossborder tax planning at Price Waterhouse Zurich, Switzerland, are Armin Marti and Jacqueline Hess