Reporting procedure for withholding tax - This changes 2023
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Until now, the withholding tax on dividends from a Swiss subsidiary to its Swiss parent company could be settled through the notification procedure, provided that the parent company holds at least 20% of the shares in the subsidiary. In the future (starting January 1, 2023), a shareholding of 10% will be sufficient.
In the international relation, there is also the possibility to settle the withholding tax by notification procedure. The minimum participation and / or minimum holding period required for this procedure are determined by the applicable double taxation agreement (DTA) between Switzerland and the country of the recipient of the dividend. To be eligible to the notification procedure, a permit (Form 823/823B/823C) is required, which was previously, once granted, valid for 3 years before it had to be renewed. As of January 1, 2023, such permits will be valid for 5 years.
Do you have any questions regarding the notification procedure or is a renewal pending? If so, please get in touch with our tax consulting - we will be happy to advise you.
