DT18104 - Double Taxation Relief Manual: Guidance by country: Switzerland: Treaty summary

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.