Conversation of CLAs in shares can be subject to Swiss withholding tax if CLAs are classified as bond or debenture and the conversion discount exceeds a certain threshold. Furthermore, interest due on CLAs may be subject to withholding tax even if payable in shares. Although the Swiss Federal Tax Administration improved their practice recently, withholding tax is still a major obstacle for a financing with CLAs. In most cases, however, it is possible to avoid negative withholding tax consequences through proper structuring of CLAs.