Switzerland – Japan Tax Treaty
The Switzerland-Japan tax treaty caps withholding on dividends at 10% for portfolio investors and 5% for qualifying direct investment, and interest at 10%. Royalties are taxed at a uniform 0% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 49 active treaties in Switzerland's network and one of 47 in Japan's. The general dividend rate of 10% is below the median in both countries' treaty networks (Switzerland: 15%, Japan: 15%).
Verified data
Swiss Federal Tax Administration (estv.admin.ch) - Double Taxation Agreements overview and treaty texts (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: Switzerland Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Switzerland) |
|---|---|---|
| Dividends (general) Portfolio investors | 10%saves 25% | 35% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 30% | 35% |
| Interest Bank interest, bonds, loans | 10% | 0% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 0% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Switzerland)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 10% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 35%.
Source: Switzerland Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 10% withholding under this treaty, compared to the 0% statutory rate. This represents a no reduction from the statutory rate.
Source: Switzerland Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 0% to 0%.
Source: Switzerland Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Switzerland Treaty Reference
Comparative Context
🇨🇭Switzerland's Network
Among Switzerland's 49 active treaty partners, the 10% general dividend rate ranks 8th (median: 15%).
| Partner | Rate |
|---|---|
| Hong Kong | 10% |
| Hungary | 10% |
| India | 10% |
| Japan (this treaty) | 10% |
| Vietnam | 10% |
| United Arab Emirates | 15% |
| Austria | 15% |
🇯🇵Japan's Network
Among Japan's 47 active treaty partners, the 10% general dividend rate ranks 2nd (median: 15%).
| Partner | Rate |
|---|---|
| United Arab Emirates | 10% |
| Switzerland (this treaty) | 10% |
| China | 10% |
| France | 10% |
| United Kingdom | 10% |