The Resource A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016

A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016

Label
A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
Title
A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
Contributor
Subject
Language
eng
Summary
Judgment by Geneva Court of Appeal, Administrative Chamber (4th Section) 19 January 2016. The taxpayer in this appeal was a dual US- and Swiss-citizen, having lived in Switzerland since 1979. She was a member of a class of beneficiaries of a trust set up by her great-grandfather. Every year, with the exception of 2006, she received approximately 40,000 CHF from a distribution by the trustee. The trust deed itself required the trustees to make distributions twice a year, though they could retain and accumulate any surplus income. The question arose whether the trust was a fixed interest trust or a discretionary trust for Swiss tax purposes. On the basis of the trust deed, the court concluded that it was a discretionary trust; the fact that the taxpayer had regularly received payments of approximately the same amount (with the exception of one year) did not render it a fixed interest trust
Citation source
In: International tax law reports. - London. - Vol. 20 (2017), part 1 ; p. 1-27
Geographic coverage
Europe
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • trust
  • wealth tax
  • trustee
  • case law
Label
A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
Instantiates
Publication
Label
A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
Publication

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