Tax Treaty Case Law around the Globe 2024
1. Aufl. 2025
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24.1. Introduction
At last year’s conference in Vienna, two excellent presentations were given on Dutch and Italian judgments addressing the relevance of amendments to the OECD Commentaries. They stood out to us personally because we knew at the time that the Swiss Supreme Court had a case in its docket turning on this issue. Handing down the judgment roughly two months later, the Court would not only go on to elaborate on the relevance of OECD Commentaries in, by its own standards, unprecedented detail but also answer some pertinent questions relating to the taxation of severance compensation in international sports and beyond. Against this backdrop, it was a particular delight for us to be invited to Tilburg this year to report on what the Swiss Supreme Court had to say on this intriguing case.
24.2. Facts of the case
On , the taxpayer, a professional footballer, signed a four-year contract with a football club based in the UAE. This contract required the footballer to take residence in the UAE for the duration of employment. Two seasons into the contract, the parties agreed to dissolve it with immediate effect. On 9 July 2013, they concluded a settlement agreement, b...