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30.01.2026

Dividends and share sales: correctly assessing international tax implications

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Why structure and residency are more important than the tax rate

Dividends from Swiss AGs are generally subject to withholding tax of 35%. For shareholders residing abroad, however, the refund is limited by the respective double taxation agreement. For German private individuals, for example, 15% definitely remains in Switzerland.

Holding structures with qualified shareholdings are significantly more efficient. German GmbHs or UK holdings benefit from virtually tax-free dividends and share sales when implemented correctly. The decisive factors here are the size of the shareholding, the holding period, and compliance with the material requirements.

Practice shows that tax optimization is not achieved through individual measures, but through consistent structuring across multiple levels.

#Dividends #Share sales #Withholding tax #DTA #Holding structure #Tax planning

https://x.com/zugtrust/status/2018715026152927711

(c) Ludwig Limbeck AG, 2026, Autor: Rolf Limbeck

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