***If you are not Swiss resident for tax purposes, this post is not relevant for you.
Dividends are different than interests . Let’s take example to make things clear for dividends. Let’s assume you own three ETFs (CHSPI, VT, and VWRL)
VWRL is domiciled in IE
CHSPI is domiciled in Switzerland
VT is domiciled in USA
Dividend withholding tax works as following (assuming you have filled W-8 BEN with your broker)
Case 1 -: Swiss broker (like Swissquote)
VWRL will have 0 withholding tax
CHSPI will have 35% withholding tax, let’s call it C1
VT will have 15% + 15% = 30% , let’s call them U1 and U2 (15% each)
Case 2 -: International Broker (like Interactive brokers)
VWRL will have 0 withholding tax
CHSPI will have 35% WHT, C1
VT will have U1 = 15% WHT , U2 = 0
How do you claim these back ?
Tax C1 is claimed under standard tax form and will be used as a credit to adjust your final tax bill
Tax U1 will be claimed using DA-1 section of tax return (ausländischer Quellensteuern)
Tax U2 will be claimed using RUS section (zusätzlichern Steuerrückbehalt USA)
In Zurich -: using online software Form DA-1 & RUS are together.
Notes -:
C1 & U2 will always be 100% credited/reimbursed because these amounts are withheld in Switzerland
For U1 special calculations are done by tax office. This is a tax credit for tax withheld in USA (for US ETFs) or other foreign jurisdictions & final tax credit will depend on few variables based on the tax return of the individual. Purpose here is to avoid double taxation
If U1 is less than 100 CHF (across all securities) for the financial year, no refund application is allowed via DA-1 form. There is no minimum amount for the U2 refund via R-US, though.
Please note this discussion is only about WHT Taxes at the level of ETF. There are also some WHT taxes which ETFs need to pay depending on which stocks they buy. That remains within the ETF performance and investor cannot claim (it is referred to as unrecoverable tax)
It works as a credit. Switzerland can’t and won’t refund what the US has kept.
That is why there are “complicated” calculations: They attribute what you call U1 to the gross dividends from which it was witheld. Then they calculate how much you would normally have to pay on those gross dividends. Finally they subtract the already paid U1 from what you would have to pay.
If your average tax rate is too low, this will be negative. They don’t “refund” this negative number because they only credit what you would have had to pay to them.
If you have debt interest, you can subtract that from your income. But they don’t tax you on the part you already subtracted. So again, they won’t credit anything that you don’t have to pay. That is why mortgage interest reduces tax credit from DA-1
I want to stress that this terminology difference is one of the main pain points in troubleshooting people’s “refunds”. It pops up again every couple months.
Switzerland will not refund foreign WHT, they will credit it to what you would have had to pay on that specific income. If you paid more, that is your problem.
Compare Swiss WHT which get refunded in full for filing taxes.
The actual discrete money amounts paid to or received from the tax office can reflect those effects or just be some (partial) net after calculation.
Just to make sure: In Zurich, using IBKR, RUS is handled automatically each year once you provided IBKR the necessary info (RUS form)? So you’ll receive 70%+15% RUS dividend payment, and then reclaim the missing 15% per DA-1?
The CHF 100 minimum applies only to U1 (DA-1), not U2 (R-US). I’ve corrected that point in the post.
From the ZH DA-1 guide:
Im Gegensatz zur Anrechnung ausländischer Quellensteuern besteht für die Rückforderung
des zusätzlichen Steuerrückbehaltes kein Mindestbetrag von CHF 100.–.
Thanks @jay
I was thinking about it if the limit is for total or just U1
Since I don’t have a personal experience on this yet. Just to be sure. If an investor only have 100 shares of VT at Swissquote, can they still apply to get 30 USD back?
Assuming 2 USD per share annual dividend & no other investments from RUS or DA 1 perspectives
Yes, that’s how I understand it. The R-US refund is unconditional (assuming it’s been declared properly with broker documents). I can’t confirm from personal experience as I never held US securities at a Swiss broker with W-8 BEN.
Yes, there is no difference between US stocks and US-domiciled ETFs with regards to DA-1. I.e., equivalent to the VT explanation in this wiki. The minimum gross dividend amount is CHF 667 (resulting in CHF 100 US WHT).
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