Before a foreign dividend reaches your brokerage account, the company's home country usually takes a cut. How big that cut is depends on three things: the country's own rate for non-residents, the cap set by its tax treaty with the United States, and whether the paperwork in your custody chain lets you pay the lower of the two.
The rates at a glance
The table shows withholding on dividends from listed companies paid to an individual U.S. portfolio investor, meaning someone owning a small percentage of the company. The column to watch is the third: what you pay when your broker or ADR depositary has documented you as a U.S. resident.
| Country | Domestic rate | U.S. treaty cap | Documented U.S. investor | How you get that rate |
|---|---|---|---|---|
| 🇦🇺 Australia | 30% | 15% | 15% | Relief at source; franked dividends 0% |
| 🇧🇷 Brazil | 10% | No treaty | 10% | Final; no treaty relief available |
| 🇨🇦 Canada | 25% | 15% | 15% | Relief at source through your broker |
| 🇫🇷 France | 12.8% | 15% | 12.8% | Form 5000 relief at source, or reclaim |
| 🇩🇪 Germany | 26.375% | 15% | 15% | Reclaim from the BZSt online portal |
| 🇮🇳 India | 20.8% | 25% | 20.8% | Domestic rate is already below the cap |
| 🇯🇵 Japan | 15.315% | 10% | 10% | Relief at source for most ADRs |
| 🇳🇱 Netherlands | 15% | 15% | 15% | Already withheld at the treaty rate |
| 🇨🇭 Switzerland | 35% | 15% | 15% | Reclaim from the ESTV on Form 82 I |
| 🇬🇧 United Kingdom | 0% | 15% | 0% | Nothing withheld on ordinary dividends |
Each country name links to its full guide with sources. Special cases (REITs, Brazilian interest on capital, Indian ADR dividends, large holdings) can differ from the rates shown.
Three numbers, not one
The domestic rate is what the country's own law charges a non-resident by default. The treaty cap is the most the country may charge a U.S. resident under its income tax treaty with the United States; for portfolio dividends it is 15% in most of the treaties covered here and 10% for Japan. Brazil has no income tax treaty with the U.S., so its domestic rate is final.
The documented rate is the lower of the two, and it is only what you pay if the institutions between you and the company know you're entitled to it. When they don't, you pay the domestic rate and have to chase the difference yourself.
Worked example
You own Swiss shares that pay $1,000 in dividends. Switzerland withholds 35%, or $350. The U.S. treaty entitles you to pay only 15%, or $150. You can credit that $150 against your U.S. tax, but the other $200 is not creditable. It comes back only if you file a refund claim with the Swiss Federal Tax Administration.
Relief at source vs. reclaim
Countries handle the treaty discount in one of two ways.
- Relief at source. The lower rate is applied when the dividend is paid, because your residence is certified through the custody chain. Canada, Japan (for most ADRs), Australia and France (through its Form 5000 process) generally work this way when the paperwork is in order.
- Refund after the fact. The full domestic rate is withheld and you claim back the excess. Switzerland and Germany are the main examples for U.S. individuals. Germany requires an electronic application to its Federal Central Tax Office; Switzerland uses Form 82 I.
For a small holding, the cost and effort of a reclaim can exceed the refund. Our guide to reclaiming foreign tax covers when it's worth doing and how ADR depositaries sometimes do it for you.
Country notes worth knowing
Countries that withhold nothing, or less than you'd expect
The United Kingdom does not withhold on ordinary company dividends, so U.S. holders receive the full amount (UK REIT property income distributions are an exception). Australia withholds nothing on fully franked dividends, those paid from profits that already bore Australian company tax, which covers many large Australian payers.
Countries where over-withholding is common
Switzerland at 35% and Germany at 26.375% both withhold well above the 15% treaty cap and generally require a refund claim. France applies 12.8% to documented individuals but 25% by default when documentation doesn't reach the paying agent, which happens with some ADRs.
Recent changes
Brazil began withholding 10% on dividends paid to non-residents on January 1, 2026, ending a long exemption. Many Brazilian companies also pay "interest on capital," which carries its own, higher rate.
The IRA exception
Foreign tax withheld inside an IRA usually can't be credited and is simply lost. Canada is the notable exception: under Article XXI of the U.S.–Canada treaty, dividends paid to a properly documented U.S. retirement account can be exempt. See foreign stocks in IRAs.
What to do with this
- Check box 7 of last year's 1099-DIV against the "documented" column above. If you paid more than you should have, find out why from your broker.
- Hold high-withholding, non-reclaimable dividend payers in taxable accounts, where the foreign tax credit can recover the tax.
- Use the withholding calculator to see what a specific holding nets after both governments.
Common questions
Why is the treaty rate higher than the domestic rate for some countries?
A treaty sets a maximum, not a minimum. If a country's own law already taxes non-residents at less than the treaty cap, as with the UK (0%), France (12.8% for individuals) and India (20.8%), the lower domestic rate applies.
Where do I see what was actually withheld from my dividends?
Your broker's year-end Form 1099-DIV shows foreign tax paid in box 7, and the foreign country in box 8. Monthly statements usually show the withholding next to each dividend.
How often do these rates change?
Most change rarely, but not never. Brazil introduced a 10% dividend tax for non-residents from January 2026, after decades of exempting dividends. We recheck every rate on this page at least annually and whenever a change is announced.
Sources
- IRS: Tax treaty tables
- IRS: United States income tax treaties, A to Z
- PwC Worldwide Tax Summaries: corporate withholding taxes
- Canada Revenue Agency: T4016, Exempt U.S. organizations under Article XXI
- Swiss Federal Tax Administration: refund of withholding tax
- Germany Federal Central Tax Office (BZSt): refund of capital gains tax
Educational content only, not investment, tax or legal advice. The Stateside Report does not recommend buying or selling any security. Tax rules depend on your situation; confirm with a qualified tax professional. Full disclosures.