Refund of Swiss withholding tax on intra-group dividends requires sufficient “substance” at recipient end on the one hand but also beneficial ownership, in the Supreme Court case below meaning economic justification to the transaction.
Michael joined our firm as an associate in 2003 and became a partner in 2012. Michael advises private clients on their domestic and international estate and tax planning, as well as on philanthropic projects and governance related questions. He acts on behalf of corporations, in particular family held companies, in domestic and cross-border tax matters. His practice also includes contentious matters before Swiss tax authorities and courts.
Marc’s practice at Froriep focuses mainly on tax law. He advises companies on national and international corporate tax law, and Swiss and foreign private clients on tax planning. Marc joined Froriep as an associate in 2014, having worked as a consultant in the private wealth team for one of the ‘Big Four’ professional services organisations, and for a business law firm in Zurich. Marc was educated at the University of St Gallen, where he gained an MA HSG in Law and Economics (2011). He was admitted to the Zurich Bar in 2014. In 2016 he qualified as a certified tax expert. His working languages are German and English.
Csilla Horber joined Froriep as a trainee lawyer in October 2018. Before joining the firm, she was a graduate research and teaching assistant at the Centre of Comparative, European and International Law of the University of Lausanne, where she worked on her Ph.D. Thesis in international intellectual property law. Csilla Horber holds a Bachelor of Law from the University of Lausanne and a Master of European and International Law from the University of Bern. In 2017, she obtained her Certificate of Advanced Studies in Legal Professions at the University of Geneva. Her working languages are French, English, Hungarian and German. Csilla Horber has not yet been admitted to the Bar.
Refund of Swiss withholding tax on intra-group dividends requires sufficient “substance” at recipient end on the one hand but also beneficial ownership, in the Supreme Court case below meaning economic justification to the transaction.
Topics: Tax
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