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HMRC internal manual

International Manual

DT Agreements: Switzerland - Income from a UK source paid to a resident of Switzerland

Claims by Stiftung (Foundations)

A Swiss foundation is a family foundation (‘fondation de famille’ or‘Familien Stiftung’) set up under the Swiss Civil Code by the founder. It isusually for the benefit of the founder, his family and sometimes certain specifiedcharitable purposes.

The foundation is incorporated under a deed (‘Acte de fondation’) by thefounder. The deed is registered under Swiss law. It is regarded as a legal entity underSwiss law and so entitled to make claims under the Convention in its own right.