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Switzerland: Double Tax Treaties

Table of Treaty Rates

Provided by TreatyPro
Switzerland


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 35% 0% when paid on loans, public issues of bonds or bank deposits 35% 0%
           
Albania Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 5% 0%
Algeria Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank, or on government bonds, or on a bank loan, or on a loan financed, guaranteed or insured by the government, or on sales on credit of equipment or merchandise 10% 0%
Argentina Signed March 20, 2014 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% on bonds or debentures paid to the government, or on a loan or credit financed, guaranteed or insured by the government or the central bank, or on sales on credit of industrial equipment or machinery, or on a bank loan granted for more than three years 12% 0% Not yet in force. Default rates apply.
Armenia Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of CHF200,000 or equivalent 15% 0% when paid on a bank loan, or on sales on credit of equipment 10% 0%
Australia Effective January 1, 2015 0% where the payee is a company holding at least 80% of the paying company's capital for 12 months before the dividend is declared, or 10% or less of the paying company's capital is held by the government, the central bank or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid to the government, the central bank, an independent financial institution or a pension fund (excluding back-to-back loans) 10% 0%
Austria Effective January 1, 1975 Protocol effective January 1, 2002 0% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% 0%
Azerbaijan Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital with a minimum investment of USD200,000 or equivalent 15% 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank, or on sales on credit of equipment 5% when paid on a bank loan, or on sales on credit of merchandise 10% 0%
Bangladesh Effective January 1, 2009 10% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on financing in connection with the selling of equipment or the construction of industrial, commercial or scientific installations or public works 10% 0%
Belarus Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on government bonds, or on sales on credit of equipment or services, or because of a transaction approved by Switzerland 5% when paid on a bank loan 8% 0%
Belgium Effective January 1, 1980 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan not represented by bearer instruments, or on sales on credit of equipment or merchandise 10% 0%
Bulgaria Effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, the central bank or a pension fund 10% 0% when paid to a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment 5% 0%
Canada Effective January 1, 1998 Protocol effective January 1, 2012 0% when paid to the central bank or a pension fund 5% where the payee is a company holding at least 10% of the paying company's voting stock 15% 0% when paid to the government, or on a loan or credit financed, guaranteed or insured by a specified institution 10% 0%
Chile Effective January 1, 2011 15% 5% when paid on a bank or insurance company loan, or on bonds or securities traded on a regulated stock market, or on sales on credit of machinery or equipment 15% 0%
China Effective January 1, 2015 0% when paid to the government 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on a loan or credit financed, guaranteed or insured by the government or the central bank 10% 0%
Colombia Effective January 1, 2012 10% where the payee is a company holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on a bank or financial institution loan, or on sales on credit of equipment or merchandise 10% 0%
Cote d'Ivoire Effective January 1, 1991 15% 0% when paid on sales on credit of equipment, goods or merchandise 15% 0%
Croatia Effective January 1, 2000 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 5% 0%
Cyprus Signed July 25, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend, or the government, the central bank or a pension fund 5% 0% 0% Not yet in force. Default rates apply.
Czech Republic Effective December 1, 1996 Protocol effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, the central bank or a pension fund 15% 0% 0%
Denmark Effective January 1, 1974 Protocol effective January 1, 2011 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0%
Ecuador Effective January 1, 1996 15% 0% when paid on government bonds, or on a bank loan, or on a loan or credit financed or insured by an institution approved by both governments, or on sales on credit of equipment, goods or merchandise 10% 0%
Egypt Effective January 1, 1989 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan, or on sales on credit of equipment or merchandise 15% 0%
Estonia Effective January 1, 2005 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government, or on government bonds or debentures, or on sales on credit of equipment or merchandise 10% 0%
Finland Effective January 1, 1994 Protocol effective January 1, 2011 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0%
France Effective January 1, 1967 Protocol effective August 1, 1998 0% where the payee is a company holding at least 10% of the paying company's capital 15% 0% 0%
Georgia Effective January 1, 2012 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 10% 0% 0%
Germany Effective January 1, 1972 Protocol effective January 1, 2012 0% where the payee is a company holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 5% when paid by a hydro-electric power company operating on the Rhine 15% 30% when paid by profit-sharing bonds 0% 0%
Ghana Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan or credit financed, guaranteed or insured by the government, or on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Greece Effective January 1, 1983 Protocol effective January 1, 2012 0% when paid to the government or a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 7% 0%
Hong Kong Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the central bank or a pension fund 10% 0% 0%
Hungary Effective January 1, 2015 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the central bank or a pension fund 15% 0% 0%
Iceland Effective January 1, 1990 New treaty signed July 10, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% When new treaty is effective: 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend, or the central bank or a pension fund 5% 0% 0% New treaty not yet in force.
India Effective January 1, 1995 Protocol effective January 1, 2001 10% 0% when paid on a loan or credit financed, guaranteed or insured by the government or a specified institution 10% 0%
Indonesia Effective January 1, 1990 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 0%
Iran Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 15% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Ireland Effective January 1, 1965 Protocol effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the central bank or a pension fund 15% 0% 0%
Israel Effective January 1, 2002 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan financed by the government or the central bank, or on sales on credit of equipment or merchandise 5% when paid on a bank loan 10% 0%
Italy Effective January 1, 1974 15% 12.50% 0%
Jamaica Effective January 1, 1995 10% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's voting stock 15% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by the government 10% 0%
Japan Effective January 1, 1971 Protocol effective January 1, 2012 0% where the payee is a company holding at least 50% of either the paying company's capital or its voting stock for six months before the dividend is declared, or a pension fund 5% where the payee is a company holding at least 10% of either the paying company's capital or its voting stock for six months before the dividend is declared 10% 0% when paid to the government, the central bank, a bank, an insurance company, a securities dealer or a pension fund, or on a loan or credit guaranteed, insured or indirectly financed by the government or the central bank, or on sales on credit of equipment or merchandise 10% 0%
Kazakhstan Effective January 1, 2000 Protocol effective January 1, 2015 0% where the payee is the central bank or a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan guaranteed or insured by the government or the central bank, or on government bonds or debentures, or on bonds or debentures paid to the government or the central bank, or on sales on credit of equipment or merchandise 10% 0%
Korea, South Effective January 1, 1979 Protocol effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the central bank, or on a loan or credit financed, guaranteed or insured by the government, or on sales on credit of equipment or merchandise 5% when paid to a bank 10% 0%
Kuwait Effective January 1, 1999 15% 10% 0%
Kyrgyzstan Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 5% 0%
Latvia Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government, or on government bonds or debentures, or on sales on credit of equipment or merchandise 10% 0%
Liechtenstein Effective January 1, 1995 35% (4) 35% (4) 0%
Lithuania Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government, or on government bonds or debentures, or on sales on credit of equipment or merchandise 10% 0%
Luxembourg Effective January 1, 1994 Protocol effective January 1, 2011 0% where the payee is a company holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend, or a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 10% 0%
Macedonia Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Malaysia Effective January 1, 1974 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 0%
Malta Effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 12 months before payment of the dividend 15% 0% where the payee is a company holding directly at least 10% of the paying company's capital for at least one year, or when paid on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Mexico Effective January 1, 1995 Protocol effective January 1, 2011 0% where the payee is a company holding at least 10% of the paying company's capital, or a pension fund 15% 0% when paid on government bonds or debentures, or on a loan financed for at least three years by the government or a financial institution to promote exports 5% when paid to a bank, insurance company or securities dealer, or on bonds or securities regularly traded on an authorised securities market 10% 0%
Moldova Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Mongolia Effective January 1, 2002 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Morocco Effective January 1, 1995 7% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 0%
Netherlands Effective January 1, 2012 0% where the payee is a company holding directly at least 10% of the paying company's capital, or a pension fund 15% 0% 0%
New Zealand Effective January 1, 1981 15% 10% 0%
Norway Effective January 1, 1990 Protocol effective January 1, 2011 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government or the central bank 15% 0% 0%
Pakistan Effective January 1, 2009 10% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 20% 10% 0%
Peru Effective January 1, 2015 10% where the payee is a company (excluding a partnership) holding directly at least 10% of both the paying company's capital and voting stock 15% 10% when paid on a bank loan, or on sales on credit of equipment 15% 0%
Philippines Effective January 1, 2002 10% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 10% 0%
Poland Effective January 1, 1992 Protocol effective July 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital for 24 months before payment of the dividend, or a pension fund 15% 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 5% 0%
Portugal Effective January 1, 1976 Protocol effective January 1, 2014 0% where the payee is a company holding directly at least 25% of the paying company's capital for 24 months before payment of the dividend, or the central bank 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to or by the government, or to the central bank, or to a company holding directly at least 25% of the paying company's capital for 24 months before payment of the interest 10% 0%
Qatar Effective January 1, 2011 0% when paid to the government, the central bank or a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
Romania Effective January 1, 1994 Protocol effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital, the government, the central bank or a pension fund 15% 0% when paid to a company holding directly at least 25% of the paying company's capital, or on a loan or credit financed, guaranteed or insured by the government 5% 0%
Russia Effective January 1, 1998 Protocol effective January 1, 2013 0% where the payee is the government, the central bank or a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital with a minimum investment of CHF200,000 or equivalent 15% 0% 0%
Montenegro Effective January 1, 2007 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 10% 0%
Singapore Effective January 1, 2013 0% when paid to the central bank 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital 15% 0% when paid to the central bank or between banks 5% 0%
Slovakia Effective January 1, 1998 Protocol effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital, the government, the central bank or a pension fund 15% 0% when paid to a company holding directly at least 25% of the paying company's capital for 24 months before payment of the interest, the government, the central bank or a pension fund, or when paid on a financial institution loan, or on sales on credit of equipment, merchandise or services 5% 0%
Slovenia Effective January 1, 1998 Protocol effective January 1, 2014 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital, or a pension fund 15% 0% when paid to a company holding directly at least 25% of the paying company's capital, the government or the central bank, or by the government or the central bank, or between banks, or on a loan financed, guaranteed or insured by a specified institution, or on sales on credit of equipment, merchandise or services 5% 0%
South Africa Effective January 1, 2010 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 5% 0%
Spain Effective January 1, 1967 Protocol effective June 1, 2007 0% where the payee is a company holding directly at least 25% of the paying company's capital for 24 months before payment of the dividend 15% 0% 0%
Sri Lanka Effective January 1, 1982 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 5% when paid to a bank or financial institution 10% 0%
Sweden Effective January 1, 1967 Protocol effective January 1, 2013 0% where the payee is a company (excluding a partnership) holding at least 10% of the paying company's capital or voting stock, or a pension fund 15% 0% 0%
Taiwan Effective January 1, 2011 10% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank, or on a loan between banks, or on sales on credit of equipment or merchandise 10% 0%
Tajikistan Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
Thailand Effective January 1, 1997 10% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% when paid on a loan financed, guaranteed or insured by the central bank or a specified institution 10% when paid to a financial institution or insurance company 15% 0%
Trinidad and Tobago Effective January 1, 1973 10% where the payee is a company holding at least 10% of the paying company's voting stock 20% 10% 0%
Tunisia Effective January 1, 1996 10% 10% 0%
Turkey Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government or the central bank 5% when paid on a loan or credit financed, guaranteed or insured by an institution to promote exports 10% 0%
Turkmenistan Effective January 1, 2014 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 10% 10%
Ukraine Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on a bank loan, or on sales on credit of equipment or merchandise 10% 0%
United Arab Emirates Effective January 1, 2012 5% where the payee is a company holding directly at least 10% of the paying company's capital 15% 0% 0%
United Kingdom Effective January 1, 1978 Protocol effective January 1, 2009 0% where the payee is a company holding at least 10% of the paying company's capital, or a pension fund 15% 0% 0%
United States Effective February 1, 1998 0% when paid to a pension fund 5% where the payee is a company holding directly at least 10% of the paying company's voting stock 15% 0% 0% Separate dividend withholding tax rules apply to REITs.
Uruguay Effective January 1, 2012 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a bank loan financed for at least three years for investment projects, or on sales on credit of equipment or merchandise 10% 0%
Uzbekistan Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 0% when paid on a loan financed, guaranteed or insured by the government, or on a bank loan, or on sales on credit of equipment or merchandise 5% 0%
Venezuela Effective January 1, 1998 0% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 0% when paid on government bonds or debentures, or on a loan or credit financed, guaranteed or insured by an institution approved by both governments 5% 0%
Vietnam Effective January 1, 1998 7% where the payee is a company (excluding a partnership) holding directly at least 50% of the paying company's capital 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid on a loan financed, guaranteed or insured by the government 10% 0%
Serbia Effective January 1, 2007 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital 15% 10% 0%

Footnotes

  1. In the case of European Union countries, the EC Parent-Subsidiary Directive can reduce dividend withholding tax to 0%, subject to certain conditions.
  2. In the case of European Union countries, the EC Interest and Royalties Directive can reduce interest withholding tax to 0%, subject to certain conditions.
  3. Switzerland's default royalty withholding tax rate is 0%. A treaty may stipulate a higher rate.
  4. The domestic rate applies.
  5. PLEASE NOTE: This table was last updated February 2015

 

 

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