With the Collective Investment Act Switzerland has introduced new types of investment funds, that is, the Société d’investissement à capital variable (SICAV), the limited partnership for collective investments (PSCI) and the Société d’investissement à capital fixe (SICAF). The Swiss Federal Tax Administration has introduced the tax regulations for a taxation of the funds and their investors at the beginning of the year. This article covers first the amended principles of taxation of funds in Switzerland and the existing uncertainties. It focuses on the international aspects like the entitlement of the funds for treaty benefits, the reimbursement by foreign investors of the Swiss withholding tax levied on distributions by the funds and the qualification of foreign funds for Swiss tax purposes.
Intertax