Exemption from withholding tax for dividend, interest and royalty payments to companies resident in Switzerland

On 4 December 2019, the Public Revenue Authority published circular Δ.2196 providing clarifications on the exemption from withholding tax (WHT) for dividend, interest and royalty payments to companies that are resident in Switzerland. The circular clarifies that, if there is no guarantee provided to the Greek tax authorities and thus the dividend, interest and royalty payments cannot be paid WHT free (based on article 63 of the Income Tax Code), the Swiss companies are entitled to request the refund of the WHT levied following the completion of the two-year period even if the dividend, interest or royalty has been paid at a moment during which the minimum 2-year period has not been completed. As a result, the treatment of Swiss companies is the same as the treatment of an EU company receiving dividend, interest or royalty payments from a Greek company.