I think then it would be 30% + 0% but then you would not be able to recover the full tax easily. Swiss tax treaty only supports refund of 15% held in US.
Yes, I believe the âadditional tax deductionâ is only applied to dividend payments that got reduced from 30% to 15%.
Correct, while you would be able to file DA-1 as usual to get a tax credit of up to 15%, youâd have to get the refund of the other 15% directly from IRS. If successful, youâd likely get a physical check by mail (with high fees to cash here).
As imprecise terminology can cause confusion, a small clarification: You never get an actual refund for the 15% US WHT deduction, the US always keeps that money. What you can get via DA-1 is a Swiss tax credit for the amount (to eliminate double taxation). Thatâs also why the DA-1 guide and some tax software/forms use the term ânicht rĂŒckforderbare auslĂ€ndische Steuernâ.
I think for all practical purposes, you are the subject matter expert on this DA-1 topics
Almost all posts in past have been very informative
Are you sure, they told me you donât need the W8-BEN to be subject to the 15+15. (Tho I still send them a scanned form so I canât say whether itâs required or not).
(Iâm fairly sure most people wonât file one, if you know someone holding US stock at PF or SQ maybe you can ask them to check how itâs reported, iirc it says explicitly the 15+15, in any case it was sufficient for DA-1)
I also donât have US stocks there. So donât know for sure. But I also did send them the form anyways
I assume what they meant is that normal account opening as Swiss resident already provides all necessary data to not require an explicit W-8 BEN. So you normally donât need to take an extra step but itâs still equivalent to filling out a W-8 BEN.
Interesting, I didnât know the US keeps that moneyâŠ
So, if someone has a total income of, say, CHF 20â000 of purely dividend income from US companies, taxed at 0.61% with CHF 122 (if you live in the city of Zurich), Switzerland will pay the person the US withholding tax of CHF 3â000 out of Switzerlandâs pocket?
No, the cap of DA-1 is (approximately) the Swiss taxes on the foreign dividends, so youâd only get a tax credit of about CHF 122 as well. In the end you wouldnât pay any Swiss taxes but youâd still pay 15% to the US via WHT.
And to add on this, there is another cap: the refund cannot exceed the amount of income taxes you have paid in CH for that year, as per SR 672.201 art. 9 al. 5:
Der Maximalbetrag darf nicht höher sein als die Summe der schweizerischen Einkommenssteuern im FÀlligkeitsjahr.
I am thinking for someone who is retired early and only have dividend income to live with.
Dividend income -: 50,000 CHF
Letâs assume , Taxable income -: 50,000 CHF
Applicable tax -: 5000 CHF (Kanton ZH, plus federal)
US WHT -: 7500 CHF
Refund -: 66%
If the dividend income was 25.000 CHF
Applicable tax -: 1400 CHF
US WHt -: 3750 CHF
WHT refund -: 37%
For such individual, US ETFs advantages would be reduced versus the UCITS range.
P.S -: to get 50,000 CHF dividends, one need to own 2,5 million CHF worth VT. Of course with other instruments such numbers can be achieved with lower capital
Not sure I fully grok this. Let me try to wrap my head around this:
If ⊠er, say ⊠a friend made, say â letâs use round numbers â 10 x the income of my friend above, i.e. CHF 200k instead of 20k.
He made US dividend (and 15% taxed at source) income of CHF 115k, and other type income (not taxed at source), with final taxable income of around CHF 200k.
Said friend then would pay about CHF 55k taxes in total (municipality of Zurich, canton, and direkte Bundessteuer). Letâs say for simplicity that the portion of Swiss taxes on the foreign dividends is 115/200=0.575 of CHF 55k = CHF 29k.
They get their US WHT of about CHF 17k from Switzerland. Itâs under the cap of CHF 29k and itâs financed via the CHF 17k â the other 15% â of RĂŒckbehalt USA.
Total DA-1 return reimbursement of CHF 34k.
Side comment if the above is roughly true:
Works for m âŠ, er, ⊠my friend, as they get the full withholding tax âbackâ, but seems unfair to my other friend mentioned above whose sole income is CHF 20â000 dividend income taxed at source from US companies. He leaves the RĂŒckbehalt USA of CHF 3â000 on Switzerlandâs table.
Kind of feels like reverse progression for Swiss based US dividend investors? See also @Abs_maxâs calculations just above.
I believe this is happening because DTAA only reduces double taxation but it doesnât reduce taxation.
So people with lower income tax slab donât get much benefit because the US tax is higher than Swiss tax in that case.
For me this is enlightenment even though maybe it was obvious. But always good to put numbers together
Though shouldnât you get back the R-US (extra 15%) at least? (Similar to how you get back the swiss withholding regardless of your tax rate)
Just to be clear ruckbehalt USA is not an issue. It would always be given back 100% because itâs just provisional tax take by SQ. if SQ deducts more than liable, everything will be refunded for sure.
The issue is only with 15% US Quellenstuer which is kind of unrecoverable
P.S -: this name Ruckbehalt USA should be changed to something else . Kind of sounds like WHT in US
Yes I just responded . @Your_Full_Name was confused a bit it seems
But with 115,000 CHF dividends , itâs alright
See, this is what confused me initially. If I understood @jay correctly, the guy making CHF 20k (his sole income) in US dividends taxed at source gets neither the WHT nor the RUS:
The Swiss tax credit for 15% US WHT is not financed via the âZusĂ€tzlicher RĂŒckbehalt USâ. The former is a reduction in Swiss taxes to (approximately) eliminate double taxation. The latter is completely separate, withheld by Switzerland, and can be ignored in this calculation (you always get the full amount back, assuming you declare it in DA-1/R-US).
Itâs not a regressive tax but it effectively results in a minimum tax rate of 15%, which is higher than the lowest tax rate in Switzerland. However, there is nothing Switzerland can do about it (assuming they canât get a better DTA with the US and the government doesnât want to simply gift you money).
I think this was mainly referring to WHT stuff. Not RUS