When Nestlé (Swiss Domiciled Company) pays a dividend of £1000 – it immediately gets taxed at the Swiss Statutory Tax Rate of 35% (£350) irrespective of who the shareholder is.
However, due to a Double Tax Agreement between the UK and Switzerland, UK residents are entitled to the preferential Double Tax Agreement Rate of 15% (£150).
Therefore, the differential of £200 (£350 – £150), is recoverable in its entirety but is retained by the Foreign Tax Office until all the necessary procedures and conditions are met.