Germany–Switzerland · Tax Refunds
eF85 · 35% → 15% · Swiss FTAReclaiming Swiss Withholding Tax as a German Resident
Swiss dividends are generally subject to 35% withholding tax. For an individual portfolio investor resident in Germany, the Germany–Switzerland double tax treaty generally allows Switzerland to retain only 15% of the gross dividend. The difference of 20 percentage points can generally be reclaimed from the Swiss Federal Tax Administration (FTA, known in German as ESTV). For income becoming due on or after 1 January 2020, German residents must apply online.
Refund Entitlement
The tax treaty generally limits Swiss withholding tax to 15%
Dividend distributions by Swiss corporations are generally subject to Swiss withholding tax at a rate of 35%.
If the dividend recipient is resident in Germany and entitled to treaty relief, Switzerland may generally impose a final tax of only 15% of the gross dividend on ordinary portfolio dividends.
The excess withholding is not automatically reduced when the dividend is paid. It generally needs to be reclaimed from Switzerland.
The Basic Principle
35% is withheld; generally, only 15% should remain
For a typical individual investor, the refund claim does not cover the entire amount of Swiss withholding tax.
Under the tax treaty, Switzerland is generally entitled to retain withholding tax of 15%.
- Gross dividend: 100%
- Withholding tax: 35%
- Final treaty tax burden: 15%
- Relief of 20 percentage points
- Refund issued by the Swiss FTA
- 15% generally relevant for the German foreign tax credit
Refund Amount
For ordinary portfolio dividends, 20% of the gross dividend is generally reclaimable
The amount is the difference between the statutory Swiss withholding tax and the withholding tax rate permitted under the tax treaty.
Tax withheld
Swiss withholding tax on the gross dividend.
Final treaty tax
The Swiss withholding tax generally permitted for an ordinary portfolio investment.
Refund
The difference that can generally be reclaimed from the Swiss FTA.
The 20% rule does not apply universally to every shareholding
Relief may differ for substantial shareholdings, pension institutions, special corporate structures or recipients who are not entitled to treaty benefits.
Electronic Procedure
German residents apply online for income becoming due on or after 1 January 2020
Individuals and legal entities resident in Germany submit Swiss withholding tax refund applications electronically for income becoming due on or after 1 January 2020.
The Swiss FTA refers to this procedure as electronic Form 85, or eF85. Applications are submitted through the Swiss online withholding tax service for Germany.
Register
Set up access to the Swiss FTA’s electronic service.
Create an application
Select the refund procedure for Germany in the withholding tax service.
Enter the income
Enter complete details of Swiss dividends and the tax withheld.
Supporting documents
Prepare the required documents and certificates.
Tax residence
Provide evidence of German tax residence.
Submit
Submit the application electronically to the Swiss FTA.
Track the status
Check the processing status in the online case overview.
Reconcile the refund
Reconcile the refund with the German tax return and foreign tax credit.
Historical cases up to 31 December 2019
For income becoming due on or before 31 December 2019, the Swiss FTA continues to refer to the former Form 85. Current cases, however, are subject to the electronic procedure.
Application Deadline
The right to a refund may be permanently lost after three years
The refund entitlement generally expires if the application is not submitted within three years after the end of the calendar year in which the taxable payment became due.
A dividend becoming due in 2026
If a Swiss dividend becomes due during the 2026 calendar year, the standard three-year period starts after the end of 2026.
The application must therefore generally be submitted within the following three years.
The three-year deadline is generally a strict forfeiture period
As a rule, it cannot simply be interrupted or extended. Refund claims should not be left until the end of the deadline.
Documents
Information required for a refund claim
Applicant
Name, address, tax residence and other identification details.
Dividend
Gross amount, due date and distribution date.
Tax withheld
The Swiss withholding tax actually deducted.
Security
Swiss company, security name, ISIN or Swiss security identification number (Valor).
Bank statement
Dividend credit advice or income statement.
Tax residence
Evidence that the recipient is tax resident in Germany.
Entitlement
Evidence that the applicant is the income recipient entitled to claim the refund.
Bank details
The account to which the Swiss refund should be paid.
Dividend statements should clearly show the gross dividend and tax withheld
Statements showing only a net credit, without a verifiable calculation of the Swiss tax, may complicate processing.
Payment
The Swiss FTA generally pays refunds in Swiss francs
According to current information from the Swiss Federal Tax Administration, refunds are generally paid in Swiss francs.
You should therefore provide details of a bank account that can receive payments in CHF.
Check your bank details before applying
If the specified account cannot receive a payment in CHF, currency conversion, bank charges and exchange rate risks may arise.
German Tax Return
The refund and the German foreign tax credit must be coordinated
Germany generally treats the gross Swiss dividend as investment income.
The portion of Swiss tax that can be reclaimed must not also be credited in Germany as foreign tax that is definitively borne by the taxpayer.
No double relief
Where 35% is withheld and the treaty provides a refund entitlement of 20 percentage points, the remaining Swiss withholding tax is generally 15%.
This remaining amount is generally the relevant starting point for the German foreign tax credit.
- Report the gross dividend in Germany
- Document the actual Swiss withholding of 35%
- Take the 20% refund entitlement into account
- 15% Swiss tax remains
- Check the German foreign tax credit limitation
Example
Refund on a gross dividend of CHF 10,000
German resident holding Swiss shares
| Item | Amount | Treatment |
|---|---|---|
| Gross dividend | CHF 10,000 | Investment income for German tax purposes |
| 35% withholding tax | CHF 3,500 | Initially withheld in Switzerland |
| Net dividend credit | CHF 6,500 | Amount credited by the bank |
| 15% final treaty tax | CHF 1,500 | Generally retained by Switzerland |
| Refund entitlement | CHF 2,000 | Generally reclaimed through eF85 |
Processing
Refunds can take several months
The Swiss FTA currently advises that processing may be delayed due to an increased number of refund applications.
For applications submitted electronically, the processing status can be tracked in the online system’s case overview.
Longer processing times do not change the application deadline
What matters is that the refund claim is submitted on time and with all required information.
Common Mistakes
What frequently goes wrong with Swiss refund claims
Not claiming a refund
The full economic burden of the 35% withholding remains.
Crediting 35% in Germany
The existing treaty entitlement to a refund is overlooked.
Missing the deadline
The entitlement may expire once the statutory deadline has passed.
Using the net amount
The gross dividend and Swiss tax are not reported separately.
Using the wrong procedure
An outdated paper form is used for income subject to the current procedure.
Incomplete bank documents
The dividend payment or tax withheld cannot be verified.
Overlooking special shareholding rules
A substantial shareholding is treated as an ordinary portfolio investment.
Claiming relief twice
The refunded amount is also retained as a foreign tax credit in Germany.
Frequently Asked Questions
Reclaiming Swiss withholding tax as a German resident
What is the Swiss withholding tax rate on dividends?
How much can an individual investor resident in Germany reclaim?
Which form is used for German residents?
Can I still submit a current application on paper?
How long do I have to apply for a refund?
Can the three-year deadline be extended?
Do I still have to report the full dividend in Germany?
Can I credit the full 35% Swiss tax in Germany?
Do I need to submit an application every year?
What if I hold 10% or more of a company?
How long does a Swiss refund take?
In which currency is the refund paid?
Further Reading
Swiss shares and withholding tax
Germany–Switzerland Tax Advice
Would you like to reclaim Swiss withholding tax?
We review treaty eligibility, the refund amount, Swiss dividend documentation and the electronic refund application, together with the correct coordination of your German income tax return and foreign tax credit.
Request a Withholding Tax Review