Letâs ignore the weighting, might be timing or index used and itâs close enough. Could you comment e.g. the 3% for France with IE-domicile, or 17.5% for Switzerland with US domicile? I did find the 15% in the DTA, but havenât read the fine-print.
Hereâs the cheeky GTP answer, not mine
France
France-US DTA: Typically, the withholding tax on dividends paid from France to the US is 15%ăsource: US-France Tax Treatyă.
France-Ireland DTA: Typically, the withholding tax on dividends paid from France to Ireland is 15%ăsource: Ireland-France Tax Treatyă.
The 3% figure for PI IE seems unusual and incorrect.
The GTP rates seem to be more accurate based on the double tax agreements and authoritative sources. The discrepancies in the PI rates might be due to incorrect assumptions or outdated information.
No I canât . I suspect some tax optimization techniques behind the scenes such as use of derivatives around ex dividend dates or whatnot. I also suspect that inside EU it is easy to move stocks to an office in the respective county to avoid WHT and then claim income from the fully own subsidiaries or something.
Or if US ETFs invest via ADRs, the withholding tax is retained at the ADR level and this loss is not visible in the fundsâ report.
This is still basically the status-quo from a practical perspective (and just market tracking).
If you will always get 100% of your DA-1, ex-US US domiciled is slightly ahead of IE on average. Plus the funds have lower TER. And you donât need multiple funds for developed and emerging markets.
But itâs very dependent on if you can ensure the full DA-1 credit.
Also you are giving the US 15% tax for free, and costing Switzerland tax revenue at the same time.
Thatâs the moral downside.
And ucits is a hedge against US regulatory risks, estate tax etc.
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