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As part of the IFA Congress 2019 held in London, the authors discuss BEPS Action 4 (interest deductibility) and its implementation in Switzerland. Interest limitation rules, as the ones proposed
As part of the IFA Congress 2019 held in London, the authors
discuss BEPS Action 4 (interest deductibility) and its
implementation in Switzerland. Interest limitation rules, as the
ones proposed in BEPS Action 4 or ruled in the ATAD of
the European Union, have not been discussed intensively in
Switzerland. Nevertheless, Switzerland has known thin
capitalisation rules for more than 20 years and has established own
regulations to prevent base erosion and profit shifting. As far as
the authors observe, there is no intention by the Swiss legislator
to change the current rules and implement new ones.
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