Dividend withholding tax is 25%
The domestic rate of dividend withholding tax is 25% plus the solidarity
surcharge. Almost all the German tax treaties reduce this to 5%, 10% or 15% on
dividends paid to foreign corporate shareholders with at least a 25% holding in
the German company.
The Swiss and – for holdings of at least 80% – US
treaties waive it altogether. Treaty provisions notwithstanding, the EU Parent/
Subsidiary Directive exempts dividends paid by a German corporation to a
shareholder incorporated in another EU country holding at least 10% for an
uninterrupted period of at least 12 months. This period does not have to be
completed before the dividend is paid; any withholding tax initially levied will
be refunded, once the minimum period has expired.
EU Forecast
euf:ba18e:147/nws-01