How to use this reference
Two layers of tax apply to any cross-border investment income: the withholding tax deducted at source in the country where the income arises, and the income tax due in the country where the investor is resident. A double tax convention caps the first and gives relief against the second. The tables below set out both sides for the Switzerland–Italy corridor.
Rates are stated as of September 2026 and are general information, not tax advice. Confirm your position with a qualified adviser in your country of residence before acting.
Swiss withholding tax (imposta preventiva)
Switzerland levies a federal anticipatory tax of 35% on dividends of Swiss companies and on interest from Swiss bonds and Swiss bank deposits. It is deducted at source and refunded on claim — for Swiss residents through the annual tax return, for non-residents through a treaty claim filed with the Swiss Federal Tax Administration.
| Income | Swiss rate at source | After treaty relief |
|---|---|---|
| Dividends (Swiss company) | 35% | 15% for an Italian resident under the treaty |
| Interest on bank deposits with a Swiss bank | 35% | Refundable in full for a treaty-resident individual |
| Interest on Swiss bonds | 35% | 12.5% for an Italian resident under the treaty |
| Royalties from Switzerland | 0% (no domestic WHT) | Treaty rate 5%, but Switzerland levies none |
| Capital gains, private investor | None | No Swiss capital-gains tax on private wealth |
| Interest / dividends of foreign issuers held in Swiss custody | None | Swiss custody alone does not create Swiss WHT |
Two points are regularly misunderstood. First, Switzerland has no capital-gains tax on the private wealth of individuals, so the withholding layer only ever touches income, never appreciation. Second, holding foreign securities in a Swiss custody account does not create Swiss anticipatory tax: a US, German or French issuer applies its own withholding rules regardless of where the account sits.
Separately, a Swiss securities transfer stamp duty applies to trades executed through a Swiss securities dealer — 0.15% on Swiss securities and 0.30% on foreign ones, split between the parties.
The Italy–Switzerland double tax convention
The convention caps the withholding the source state may keep:
- Dividends — 15%. An Italian resident receiving a Swiss dividend reclaims the 20 percentage points above the treaty rate.
- Interest — 12.5%. Bank deposit interest is generally fully refundable to an individual treaty resident.
- Royalties — 5%, though Switzerland levies no domestic withholding on royalties in the first place.
- Private pensions are taxable only in the state of residence.
Italian withholding tax on the other side
Italy applies a general 26% rate to financial income — dividends, most interest and capital gains — with a reduced 12.5% on government bonds and equivalent white-listed issues. A Swiss resident receiving Italian dividends claims down to the 15% treaty rate, either at source where the paying agent allows it or through a refund claim afterwards.
| Item | Italian rate | Notes |
|---|---|---|
| Dividends paid to a non-resident individual | 26% | 15% under the treaty, or a partial refund claim |
| Interest on Italian bonds (titoli di Stato) | 12.5% | Often 0% for residents of qualifying white-list states |
| Interest on Italian corporate bonds / deposits | 26% | 12.5% under the treaty |
| Foreign financial income of an Italian resident | 26% substitute tax | Applied to the net-of-foreign-tax amount in many cases |
| Foreign asset wealth tax (IVAFE) | 0.2% per year | On the value of foreign financial assets |
An Italian resident holding a Swiss account also has reporting duties independent of tax: foreign assets go in quadro RW of the annual return, and IVAFE, a wealth tax of 0.2% per year, applies to the value of foreign financial assets. Where income is collected without an Italian resident intermediary, the 26% substitute tax is self-assessed in the return, and relief for the foreign tax follows the netto frontiera rule rather than a full foreign tax credit.
Reclaiming Swiss anticipatory tax: the procedure
- Obtain the tax voucher from the custodian bank showing the gross income and the 35% deducted.
- Complete the refund claim form for your country of residence, published by the Swiss Federal Tax Administration.
- Have your local tax office certify your residence on the form (or attach a residence certificate where the form allows it).
- File with the Federal Tax Administration in Bern within three years of the end of the calendar year in which the income fell due.
- The refund is paid by bank transfer, typically within a few months, in Swiss francs.
Many custodians will handle the filing on the client's behalf, some for a fee and some only for selected countries. It is worth asking before the relationship starts, because the difference between a reclaimed and an unreclaimed 20 percentage points on a dividend-paying portfolio is material over time.
Portfolio implications
- A non-resident who cannot reclaim efficiently is structurally penalised on Swiss dividend payers; the after-tax yield, not the headline yield, is what matters.
- Bond coupons from non-Swiss issuers held in Swiss custody escape the 35% deduction entirely, which is one reason directly held international bonds suit non-resident portfolios.
- Fund domicile changes the arithmetic: withholding suffered inside a fund is usually not reclaimable by the end investor.
- Every reclaim has a cost in time and paperwork. Below a certain position size the friction can exceed the recovery.
Sources
- Swiss Federal Tax Administration — Anticipatory Tax (Swiss Withholding Tax), on the 35% rate and the refund system.
- Swiss Federal Tax Administration — Forms for the refund of anticipatory tax, residence abroad, country-by-country claim forms.
- Convention between the Swiss Confederation and the Italian Republic for the avoidance of double taxation — treaty text (dividends, interest, royalties, pensions).
- Fiscomania — Tassazione investimenti finanziari esteri e quadro RW, on the 26% substitute tax, IVAFE and reporting duties.
- Fiscomania — Rimborso della ritenuta su dividendi esteri, on refund claims and the netto frontiera mechanism.
Last reviewed September 2026. Tax rates and treaty practice change; verify against the primary sources above before relying on a figure.