TLDR: Swiss investment funds can directly apply for treaty benefits on French-source dividends, provided that at least 80% of their income comes from foreign sources. The application is made using forms RF 2, RF 6, or RF 7, accompanied by a supplementary sheet RF b, within six months after the close of the accounting period. The files are submitted to the Swiss Federal Tax Administration in Bern, which verifies and forwards them to the French General Tax Directorate.
Eligibility conditions
The procedure applies exclusively to Swiss-based investment funds where at least 80% of their income comes from foreign sources.
Forms and deadlines
You must use one of the following forms: RF 2, RF 6, or RF 7. The application must be submitted within six months after the end of the accounting period and must include all French-source income received during that period.
Supporting documents
Each application must be accompanied by a supplementary sheet RF b indicating the total value of the fund's assets.
Submission of applications
Applications are sent directly by the fund management to the Swiss Federal Tax Administration in Bern. The latter verifies, certifies, and forwards the files to the French General Tax Directorate.
Unchanged process
The process set out in the exchange of letters between the Swiss and French competent authorities dated 12 March and 26 May 1970 remains applicable. The Swiss Federal Tax Administration retains the copy intended for it and sends the other copies to the Directorate for Non-Residents and General Services.
Scope of benefits
Swiss investment funds can directly apply, up to the amount of French-source dividends received and attributable to certificate holders resident in Switzerland, for the treaty benefits provided for this category of income.
Exclusions
No other conditions or requirements are necessary for the application of this procedure. Funds that do not meet the 80% foreign income criterion are not eligible.