Insights

Optimising Swiss Withholding Tax Refunds for Non-Swiss Investors

Stephanie Eichenberger 30 May 2025

An overview by Tax Partner AG, Taxand Switzerland

Optimising Swiss withholding tax refunds has evolved from a purely administrative task into a critical strategic consideration in cross-border investment planning. Non-Swiss investors must carefully select their investment vehicles to minimise tax leakage and enhance returns.

Stephanie Eichenberger and Thomas Zellweger from our Swiss firm Tax Partner AG have recently published an article in the ITR (International Tax Review) examining how different Swiss and foreign fund and holding structures influence eligibility for Swiss withholding tax refunds.

Key points covered in the article include:

• The impact of Swiss investment funds, which are generally tax-opaque and subject to 35% withholding tax, on refund eligibility.
• The advantages of foreign investment funds and treaty benefits that can reduce withholding tax rates.
• Substance requirements and beneficial ownership criteria for holding companies to qualify for treaty relief.
• Risks and considerations associated with offshore holding companies and Swiss holding companies.
• Challenges and conditions for foreign foundations seeking withholding tax refunds.
• The importance of thorough documentation and compliance with Swiss Federal Tax Administration rules to successfully reclaim withholding tax.

You can read the full ITR article here to learn how to reduce tax leakage and optimise your structure for Swiss equity investments.

Article tags

Cross border | Investments | Switzerland | Tax Relief | Withholding Tax