Non-resident - withholding dividend/coupon tax on Vanguard index funds held in a vested benefits account

Hi everyone!

I’m a French resident. Used to work in CH, but no longer - and don’t have any work permit anymore.
I have a vested benefits account in which I can invest in Vanguard accumulating index funds based in Ireland (ETFs too, but since I can use index funds, I’d rather go for them). They’re here:
I could withdraw at least part of the account since I left CH, but taxation would be high (social charges in FR on top of the 6.75% tax) and for now, I plan to live in FR - later, I might be able to minimize this tax. So even though investing in the vested benefits account ends up costing me in the 0.5-0.6% all fees included, I find it a decent deal for keeping my money invested, with good security, in CH.

I’m thinking of investing in Global Stock Fund and Global Bond Fund (maybe 1 or 2 more), both acc EUR. This way, as a FR resident, I don’t need to bother with dividend declarations - and it also costs me a lot to reinvest the dividends within the vested benefits account frame.

The question that remains is if the dividends/coupons from the index funds are subject to Swiss 35% withholding tax, because that is a deal breaker (if I end up paying 0.7-1% more in taxes on top of the 0.5-0.6% in fees)
From what I understand:

  • L1TW - dividends will be taxed by each country (eg US at 15% etc)
  • L2TW - no Irish tax
  • L3TW - this should be based on my fiscal residence (FR) so in theory CH should not tax me

Also, I understand that foreign acc funds should not be subject to it (, but I’ve read a few contradictory reports.

So, if anyone has all the data on this, I would really appreciate it.

I believe I wouldn’t be the only one here interested in knowing where (at which institution) this vested benefits account is held, if you’d be willing to share?

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(Why) Do you have to declare dividends in France? The vested benefits account is part of a foreign (Swiss) pension system, and as such shouldn’t be taxed before withdrawal, shouldn’t it?

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Afaik, it shouldn’t be taxed on your personal level, as long as it remains within a foreign pension system that’s recognized by France - or the EU, by virtue of the social security agreement?

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Yeah I assume if it’s a pillar 2 there shouldn’t be any taxation (or even declaration?) needed in France (but do you homework ;)), also no taxation in Switzerland.

Taxation normally happens at withdrawal (at which point might be worth to move to a low tax country for 6 months :slight_smile:)

Unfortunately, I’ve not been able to find something very straightforward about this.
Best I could find was these materials on the convention:

You might think that with the PEPP pension project in the EU, things would get clearer on making pension plans more transparent between countries…

I took a while to investigate (quite a lot)
I will share briefly:

  • Liberty has an option (called open fund universe) where you can go and buy any FINMA fund basically, which also includes Vanguard index funds, starting from certain amounts though. Unfortunately, after telling me about 0.45% fees in general, they told me later that for this open universe it’s actually 0.6% - so when adding up the Vanguard fees, I get to 0.8-0.9% which is too high for me.
  • in principle, I still have to declare the dividends, unless they’re reinvested. I’ve looked up the conventions and couldn’t find much useful. I should ask directly FR tax department I guess.
  • for the withholding tax, basically IE or Lux funds don’t have a problem with this (so a Vanguard fund is fine - confirmed by Vanguard guys directly to me) and Swiss funds invested via Viac for instance are invested by the foundation (which is tax exempt), so they retrieve it. For other vested benefits plans, I do not know.
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