Michael Grebe

The reporting procedure for capital gains tax on dividends (MiKaDiv) marks a turning point in Germany’s withholding tax landscape. Starting February 1, 2027, paying agents must submit electronic reports to the Federal Central Tax Office—a requirement that has significant implications for Swiss and other foreign custodians. This article analyzes the new obligations, the information requirements throughout the custody chain, and the consequences of incomplete data reporting for the market position of Swiss custodians.