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8.2.2.1. Withholding Tax Rate Determination

The Federal withholding tax is levied at the Swiss source on certain types of investment income, lottery gains, and insurance benefits.

The tax is levied and paid by the debtor of the taxable income. The debtor is required to withhold the tax irrespective of the qualifications and identity of the recipient. The Swiss resident recipient may, in general, recover the tax by means of a refund. In some specific cases only, the levy and payment of the tax is replaced by a notification procedure. For non-residents, the withholding tax is a final tax burden, unless a double tax treaty between Switzerland and the state of the recipient’s residence provides for relief. In some specific cases an international notification procedure or a reduction-at-source procedure is applicable (see 8.2.3.3).

When making a determination of the applicable withholding tax rate it is important to keep in mind that domestic withholding tax rates can be overridden by withholding tax rates provided for in an income tax treaty that is in effect, as well as withholding tax rates under relevant EU directives and other potentially applicable multilateral instruments. The table below lists the withholding tax rates from all sources on 9 different cross border payments where the recipient is a US corporation.

ToolName:WithholdingTaxRates Argument:PayingCountryCode=(CountryCode),ReceivingCountryCode=US