This country-by-country guide provides a comprehensive overview of dividend withholding tax reclaims worldwide, helping institutional and professional investors identify reclaim opportunities, understand local requirements, and assess operational complexity in 2026.
Dividend withholding tax is often deducted at source at rates higher than those agreed under:
applicable double tax treaties (DTT);
local tax law exemptions;
those claimable under the free movement of capital provision in the EU Treaty.
This guide explains where excess tax may be reclaimed, who may be eligible, and what investors should expect from the reclaim process in each jurisdiction.
Why dividend withholding tax reclaims are often missed
Despite established tax treaty frameworks, a significant amount of reclaimable withholding tax remains unclaimed each year.
Common contributing factors include:
Complex and opaque reclaim procedures
Fragmented custody and settlement chains
Beneficial ownership uncertainty
Internal resource constraints or prioritisation challenges
Where a jurisdiction is known for particularly high reclaim friction or, conversely, strong recovery potential, this is highlighted in the country commentary.
How to use this guide
This guide is designed as a practical reference for investors, tax teams, and asset managers navigating dividend withholding tax recovery across multiple markets.
It is not intended, nor does it (necessarily also) apply to (high net worth) individuals.
For each country, you will find structured information addressing reclaim eligibility, process considerations, documentation expectations, and timing. Statutory and treaty withholding tax rates are presented separately in a consolidated table for ease of comparison.
Some key concepts for dividend withholding tax reclaims
Statutory vs. Treaty Withholding Tax Rates
Dividend income is typically subject to a statutory withholding tax rate in the source country. Where a double tax treaty applies, a reduced treaty rate may be available. When withholding occurs above the treaty rate, investors may be entitled to an exemption (“relief-at-source") or to reclaim the excess tax.
Beneficial Ownership Requirements
Beneficial ownership is a central requirement in dividend withholding tax reclaims and varies significantly by jurisdiction.
Beneficial ownership can be:
Explicitly defined in domestic law or administrative guidance, or explained in case law
Subject to heightened scrutiny by tax authorities
A frequent cause of reclaim challenges or denials, as beneficial ownership is almost always a condition under tax treaties but almost never defined under those same tax treaties
Understanding local beneficial ownership standards is critical for investors, especially when holding securities through intermediated or pooled investment structures.
Eligible Investor Types
Eligibility to reclaim dividend withholding tax depends on investor-specific factors, including:
Legal form and tax residency
Classification as a pension fund, investment fund, insurance company, corporate entity, or individual
Transparency or tax-exempt status under local law
Each country profile in the table below identifies which investor types are generally eligible to reclaim and flags any notable exclusions or preferential regimes.
Reclaim Deadlines and Processing Timelines
Dividend withholding tax reclaims are subject to statutory limitation periods, which typically range from one to several years depending on the jurisdiction.
When not contained in the treaty, the applicable statute of limitations is the one that applies under the domestic tax law of the source country. While statutes of limitations can sometimes be generous, it is strongly recommended to submit reclaims as soon as possible: not only because of the time value of money and opportunity cost, but also because statutes of limitations are not always so clear, can be subject to change, and submitting reclaims does not always suspend statutes of limitations.
Documentation and Practical Complexity
Documentation requirements differ widely between countries and are a major driver of reclaim cost and feasibility.
As a general rule, all countries require the following documents:
power of attorney (if the applicant is applying on behalf of another person),
certificate of tax residence of the applicant from the applicant’s residence country tax authorities, and
dividend tax certificates (also known as dividend vouchers; these are documents issued by the paying agent or custodian bank).
Proof of beneficial ownership (in the event the applicant owns the securities generating the dividend income directly, the dividend voucher is often sufficient; in the event of intermediated or pooled investment structures, the structure and arguments for beneficial ownership will need to be described in detail)
In addition to these documents, any reclaim application should include at least:
State the full name of the applicant
State the relevant dividend payment(s)
Amount of tax withheld
Legal basis for the reclaim (for example the tax treaty article relied upon)
Refund amount claimed
Details of the bank account to which refunds can be transferred.
For more detailed information, you can visit each country’s guide on our website.
The table below summarizes the country-specific documentation categories commonly requested by the competent tax authorities.
Dividend withholding tax reclaims per country
|
Country |
DWHT Rates |
Reclaim available |
Eligible investors |
Reclaim process |
Documentation |
Deadlines |
|
Australia |
Standard rate of 30% (franked dividends exempt) |
yes |
Non-resident investors under applicable treaties |
Reclaim possible; relief at source through treaty rates |
Form NAT 75265 |
4 years from payment date; 6 years if good reasons are provided for the delay |
|
Austria |
Standard rate of 27.5% |
yes |
Non-resident investors under applicable treaties |
Refund reclaim; relief at source generally not available |
Form ZS-RD-DIAG; Holding period/ economic ownership statements |
5 years from end of calendar year |
|
Brazil |
10% withholding tax on dividends |
yes |
Foreign investors; statutory exemption for qualifying foreign pension funds and sovereign wealth funds |
Statutory exemption at source for qualifying investors; ETR-based credit or refund mechanism available post-withholding where combined taxation exceeds nominal corporate rate |
Reclaim documentation to be determined/ issued as Jan 2026 |
5 years from income pay date |
|
Canada |
Standard rate of 25% |
yes |
Non-resident investors entitled under tax treaties |
Refund reclaim for excess withholding; relief at source commonly applied |
Form NR7-R |
2 years from end of calendar year |
|
France |
Standard rate of 25% |
yes |
Non-resident investors entitled under tax treaties |
Refund procedure for excess withholding; relief at source may apply in limited cases |
Form 5001 Form 5000 Certain treaty specific forms may apply depending on the applicant’s country of tax residence |
2 years from end of calendar year |
|
Germany |
Standard rate of 26.375% (including solidarity surcharge) |
yes |
Non-resident investors entitled under tax treaties |
Refund reclaim for excess tax; relief at source available under certain conditions |
No form. Filing through web portal. ECJ reclaims cannot |
4 years from end of calendar year |
|
Ireland |
Standard rate of 25% |
yes |
Non-resident investors qualifying for exemptions or treaty relief |
Relief at source commonly available; refund reclaim if excess withheld |
Form V2A for relief at source; Form V2B for reclaim |
4 years from end of calendar year |
|
Luxembourg |
Standard DWHT rate of 15% |
yes |
Non-resident investors entitled under tax treaties |
Reclaim of excess withholding tax through refund procedure; treaty relief possible. |
Form 901bis |
Statutory deadline of 5 years. Under most tax treaties, the statute is only 2 years from the end of the calendar year |
|
Netherlands |
Standard rate of 15% |
yes |
Non-resident investors entitled under tax treaties |
Refund reclaim for excess withholding tax. Relief at source possible under certain conditions (can be confirmed by advance ruling) |
Filing is electronic via web portal or integration API with Dutch tax authorities |
3 years from end of calendar year (may be extended to 5 years at the discretion of the tax authority) |
|
South Korea |
Standard rate of 22% (including local surtax) |
yes |
Foreign investors eligible under tax treaties |
Refund claim for excess withholding tax. Relief at source possible under conditions |
Form 72-2 for relief at source; Form 72-3 if no relief was applied (reclaim form); Form 29-13 if applicant is overseas investment vehicle |
5 years from income event pay date |
|
Spain |
Standard rate of 19% |
yes |
Non-resident investors entitled under tax treaties |
Refund reclaim mechanism; Relief at source possible in limited cases |
Form 210 (IRNR) |
4 years |
|
Switzerland |
Standard rate of 35% |
yes |
Non-resident investors entitled under double tax treaties |
Reclaim of excess tax via refund; No relief at source. |
Specific country forms (although most forms are almost identical) |
3 years from end of calendar year |
|
United Kingdom |
0% on ordinary dividends 20% on dividends from real estate investment trusts (“REITs”) |
|
|
Relief at source under certain conditions; Reclaim is standard. |
Form R43 for reclaim of over withheld tax on REIT distributions |
4 years from end of calendar year |
|
United States |
Standard rate of 30% |
yes |
Non-resident investors eligible under tax treaties |
Relief at source via treaty rate; refund reclaim if excess withheld |
IRS Form W-8-BEN-E (beneficial ownership statement); Form 1120F Form 1042S (proof of withholding) |
3 years from end of calendar year |
Below, the links to each Country's in-depth guide:
Double Tax Treaty updates 2026
In 2026, a number of new, amended, or newly effective double tax treaties (DTTs) will play an increasingly important role in determining the final withholding tax burden on cross-border dividend payments, as well as the availability of withholding tax (WHT) reclaims. For investors and intermediaries, staying aligned with these treaty changes is essential, particularly in cases where domestic withholding continues to be applied at source at rates exceeding treaty limits.
One of the most significant developments is the new China–Italy tax treaty, which will apply to dividends from 1 January 2026 and introduces reduced WHT rates of 10%, subject to holding-period conditions. This represents a material improvement compared with domestic withholding and is likely to give rise to increased reclaim activity where relief at source is not operationally available.
Alongside this, China’s updated treaty with Brazil also take effect in 2026, introducing clearer dividend withholding caps and tiered WHT rates linked to investor status and ownership thresholds. These changes reflect a broader trend toward more granular treaty provisions, which, while offering potential tax savings, may also require more detailed documentation and post-payment reclaim procedures.
Beyond China-related treaties, Brazil and Poland have signed a new tax treaty expected to apply from 2026, and India and France have agreed on a revised treaty framework that would rebalance dividend taxing rights between the two jurisdictions, subject to ratification.
Taken together, these developments underline the importance of treaty monitoring in 2026, as reduced dividend WHT rates under revised or newly applicable treaties will often only be recoverable through formal refund or reclaim processes rather than automatic relief at source.
|
Treaty / Protocol |
Applies From |
Dividend WHT Provisions Relevant for Reclaims |
|
China – Italy DTT |
1 January 2026 |
5% WHT for ≥25% shareholding held for 365 days; 10% in other cases |
|
China – Brazil Protocol |
1 January 2026 |
5% (government/financial institutions), 10% (≥10% shareholding), 15% otherwise |
|
Brazil – Poland DTT |
Expected 1 January 2026 |
Dividend WHT ceilings generally between 10% and 15%, subject to conditions |
|
India – France Treaty Revision |
Pending ratification |
Proposed 5% WHT for >10% shareholdings; up to 15% for minority holdings |
Scope and Limitations
This guide is intended as a strategic and operational reference, not as formal tax advice. Local practice, administrative guidance, and treaty interpretation may change, and outcomes depend on investor-specific facts.
For jurisdictions with frequent regulatory updates or inconsistent administrative practice, we recommend confirming current requirements before filing.
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