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Direct Tax
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
April 28, 2026
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  • Swiss taxpayers will gain some welcome tax repayments from the government after amendments to the Federal Withholding Tax Act (WHTA) entered into force. Olivier Eichenberger of KPMG Switzerland discusses the changes.
  • The Swiss financial centre offers the expertise and access to the financial markets required for financing activities and is the headquarters for many international groups. Rolf Wüthrich and Noëmi Kunz-Schenk of burckhardt discuss the proposed changes being made to the legal framework that will further strengthen the financing activities of groups in Switzerland.
  • The term “substance” in the tax practice can have very different meanings. Peter Brülisauer of Deloitte discusses how it is of fundamental importance for the purposes of a substance-based analysis.

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