What are Switzerland's treaty withholding rates on dividends and interest?

Switzerland's domestic withholding rate on dividends and interest is 35% (Verrechnungssteuer). Double tax treaties reduce this rate for eligible foreign recipients. For dividends from portfolio shareholdings (typically below 10%), the treaty rate is most commonly 15%. For substantial shareholdings (10% or more), many treaties reduce the rate to 5% or even 0% — reflecting the principle that dividends between parent and subsidiary should not be heavily taxed at source.

Interest on Swiss bonds and bank deposits is also subject to the 35% Verrechnungssteuer. Treaty rates on interest are typically 0% or 5% under most OECD-model treaties. This means qualifying foreign creditors can reclaim nearly the full 35% withheld on Swiss bond interest by filing the appropriate form with the FTA. Key treaty partners and their dividend rates include: Germany (15% portfolio, 5% for 10%+ holdings), UK (15% portfolio), US (15% portfolio, 5% for 10%+ under the US-Switzerland DTA), and France (15% portfolio).

To obtain reduced rates, foreign recipients must actively apply using the FTA's treaty refund forms (R-82 for general use, Form 82 E/82 R for specific cases). Claims must be filed within three years of the withholding date in most cases. Swiss resident companies and individuals recover the full 35% automatically via their annual tax return rather than a separate refund procedure.

This is general information only, not professional tax advice. Consult a qualified tax professional for your specific situation.