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5.4. Tax Base for Non-Resident Entities

Non-resident entities are taxed based on their income generated in a Swiss branch, their profits as a partner of a business in Switzerland (e.g. partner of a general or limited partnership) and their net income from Swiss real estate. Also subject to Swiss tax are interest payments for loans that are secured through Swiss real estate and commissions or other earnings from trading with real estate in Switzerland. Tax base is the Swiss sourced income.