Swiss Withholding Tax on Dividends: How Foreign Investors Reclaim the 35%
Switzerland withholds 35% on dividends from Swiss companies, the highest rate a European portfolio usually meets. A client resident in a treaty country keeps most of it only by filing: the Swiss withholding tax refund is claimed from the Federal Tax Administration (ESTV) after payment, and the claim lapses three years after the end of the year the dividend fell due. For a client with a sizeable Swiss holding, a missed year is real money.
What is withheld
The Verrechnungssteuer on investment income is 35% of the taxable payment (VStG Art. 13(1)(a)), deducted by the Swiss company from the dividend. A person resident abroad can claim a refund from the ESTV only where a double taxation treaty applies, and only down to the rate the treaty lets Switzerland keep.
Treaty rates by residence
The official table published by the State Secretariat for International Finance and the ESTV (as at 1 January 2026) gives, for portfolio dividends (“Règle”), the part of the 35% that is refunded and the residual Swiss tax:
| Residence of the shareholder | Refunded | Swiss tax kept | ESTV form |
|---|---|---|---|
| Germany | 20% | 15% | 85 |
| France | 20% | 15% | 83 |
| United Kingdom | 20% | 15% | 86 |
| Netherlands | 20% | 15% | 81 |
| Austria | 20% | 15% | 84 |
| Italy | 20% | 15% | 95 |
| Spain | 20% | 15% | 90 |
| Ireland | 20% | 15% | 91 |
| Sweden | 20% | 15% | 80 |
| Norway | 20% | 15% | 87 |
| Finland | 25% | 10% | 88 |
Lower residual rates in the same table apply to companies holding a substantial participation; the table notes that they are in principle available only where the holding belongs to a company. The table also notes that the part Switzerland does not refund is in principle creditable against income tax in the other state, which is why the residence normally gives a credit for the 15% (or 10%) and not for the full 35%.
The deadline: three years, then it lapses
VStG Art. 32(1): the right to a refund lapses if the application is not filed within three years after the end of the calendar year in which the taxable payment fell due. A dividend due in 2026 can be claimed until 31 December 2029. A dividend due in 2023 had to be claimed by 31 December 2026, eight weeks from the date of this article. The ESTV notes that a treaty can set its own limit; Borderfolio shows the statutory date without checking each treaty.
How to file
- The form for the residence. The ESTV publishes one refund form per treaty country, found on that country's treaty page under “Formulare”. The form numbers above are the ones in the treaty table.
- Online only for German residents. Residents of Germany can file through the VST-DE portal; the ESTV page gives no online route for other countries.
- Once a year. The ESTV usually accepts one application a year from the same claimant, so a year's dividends go on one claim.
- Evidence. Attach income statements or the securities list; for shares held at a foreign bank, the tax voucher.
- Timing and currency. The ESTV does not confirm receipt and says processing can take several months; refunds are generally paid in Swiss francs, with currency risk and fees borne by the claimant.
A worked example
Illustrative figures. A UK-resident client receives CHF 10,000 of gross dividends from Swiss shares in 2026.
- Withheld at 35%: CHF 3,500. The client receives CHF 6,500.
- Treaty residual 15%: CHF 1,500 stays in Switzerland. Refundable on Form 86: 20% = CHF 2,000, claimable until 31 December 2029.
- After the refund the client has CHF 8,500 of the 10,000, and the CHF 1,500 is the foreign tax the UK return may credit.
- The same dividends for a Finnish resident: CHF 2,500 refundable on Form 88, CHF 1,000 kept by Switzerland.
Without a claim, the UK client loses CHF 2,000 a year that the treaty would have returned. The treaty table describes only the part Switzerland does not refund as creditable at home, so a home credit does not make up for a missed claim.
Pillar 3a and funds
Securities held for a client in a pillar 3a account are a different case: the bank foundation reclaims the Swiss tax, and the account holder has no refund claim of their own (ESTV Kreisschreiben Nr. 18a, section 10). Swiss tax withheld inside a fund is likewise the fund's matter. See tax-advantaged investment accounts across Europe.
What Borderfolio shows
For a client resident in the EU-27, the United Kingdom or Norway who holds Swiss shares directly, the Cross-Border tab shows each holding withheld at 35%, the treaty rate for the residence from the official table, what may be reclaimable a year and “Claim by 31 Dec … · ESTV refund form” (for German residents, the VST-DE online route). The Overview lists firm-wide the Swiss claims from earlier years' dividend records that close within six months, so a 2023 dividend shows up before its 31 December 2026 deadline. Not modelled: substantial-participation rates, withholding inside funds, and treaty-specific claim periods. The same finding covers five other European source countries.
Not tax advice. Rates, routes and deadlines are summarised from the sources listed below as read on 3 November 2026; treaties, forms and portals change. Confirm the position for each client with the source country's authority or a tax adviser before filing.
Sources: Verrechnungssteuergesetz (VStG), Art. 13 and 32, ESTV, refunds of withholding tax, ESTV, refund forms for residents abroad, SIF/ESTV, treaty relief on Swiss dividends and interest, as at 1 January 2026, ESTV Kreisschreiben Nr. 18a (pillar 3a).
Frequently asked questions
How much of the Swiss 35% withholding tax can a foreign investor get back?
It depends on the treaty. For portfolio dividends, the official Swiss table shows 20 of the 35 points refundable for most European residences (Germany, France, the UK, the Netherlands, Austria, Italy, Spain, Ireland, Sweden, Norway), leaving 15% in Switzerland, and 25 points for Finland, leaving 10%.
What is the deadline for a Swiss withholding tax refund?
Under VStG Art. 32(1) the claim lapses unless it is filed within three years after the end of the calendar year in which the dividend fell due. Dividends due in 2026 can be claimed until 31 December 2029; dividends due in 2023 until 31 December 2026.
Can the refund be filed online?
The ESTV offers an online route, VST-DE, for residents of Germany. Residents of other countries file the ESTV refund form for their country of residence.