SolvedDT18104 | Double Taxation Relief Manual: Guidance by country: Switzerland: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Switzerland are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | Article 10 |
| Dividends on direct investments | 0% (note 1) | Article 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner is a company controls, directly or indirectly, at least 10% of the capital in the company paying the dividends | Article 10 |
| Property income dividends | 15% | Article 10 |
| Interest | 0% | Article 11 |
| Royalties | 0% | Article 12 |
| Government pensions | Taxable only in Switzerland unless the individual is a resident of and national of the UK | Article 19 |
| Other pensions | Taxable only in the UK | Article 18 |
| Arbitration | Yes | Article 24 |
Note 1: The zero rate also applies where the beneficial owner of the dividend is a pension scheme.