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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Switzerland: Dividends

The Swiss tax deducted from dividends paid by a Swiss company at the agreement rate of 15 per cent (5 per cent if the recipient is a United Kingdom company controlling, directly or indirectly, at least 25 per cent of the voting power in the company paying the dividend) qualifies for credit as a direct tax (see DT950(c)). The reductions to the above rates are not given where the dividends are effectively connected with (see DT214 fifth sub-paragraph) a permanent establishment or fixed base which the recipient has in Switzerland.

Where a dividend is paid to a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Swiss company paying the dividend, credit may also be given for the underlying tax (see DT950(d)).