How can Foreign Investors Recover Dividend Withholding Tax on Custodian Property Income REIT PLC Property Income Distributions?

Consider a UK investor holding shares in a Swiss-domiciled company. When that company pays a dividend of £1,000, Swiss tax law requires an immediate withholding of 35% (£350), applied automatically regardless of who the shareholder is.

Because of the Double Tax Agreement between the UK and Switzerland, however, that investor is entitled to a reduced rate of 15% (£150) on the same dividend.

This leaves a shortfall of £200, the difference between the standard 35% withholding and the 15% treaty rate. That £200 is fully recoverable, but it sits with the Swiss tax authority until the correct claim procedure has been completed and all conditions have been satisfied.