Citation: Sophia Ritzmann, Petrit Ismajli, Michael Grebe, Olga-Vasiliki Plousiou, Impact of MiKaDiv reporting in Germany on Swiss custodians, in zsis) 2/2026, A4, N [...] (publ.zsis.ch/A4-2026)
The MiKaDiv reporting procedure will take effect on February 1, 2027, and will revolutionize the processing of capital gains tax on dividends from German stocks. For foreign investors, electronic reporting will be a prerequisite for withholding tax relief in the future—without it, refunds will no longer be possible.
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The MiKaDiv reporting procedure will take effect on February 1, 2027, and will revolutionize the processing of capital gains tax on dividends from German stocks. For foreign investors, electronic reporting will be a prerequisite for withholding tax relief in the future—without it, refunds will no longer be possible. Swiss custodians are also affected. They must provide complete and timely data throughout the custody chain. Missing information will result in definitive withholding tax charges of 26.375% for clients. The data requirements are extensive and cover both investor and transaction information. While the German tax authorities assume that most data is already available through regular business processes, the reality paints a different picture: Data points must be identified for omnibus accounts, indirect client relationships, and tax-transparent structures. Swiss custodians should decide by mid-2026 how they intend to implement MiKaDiv in order to be fully operational by the end of 2026.
1. Introduction: MiKaDiv and Its Current Relevance
The notification procedure for capital gains tax on dividends from shares and depositary receipts (MiKaDiv) represents a central component of the digitization of the German withholding tax system. Following several delays, particularly due to harmonization with the European FASTER Directive, MiKaDiv will now take effect on February 1, 2027.01 The aim of the reform is not only t
Impact of MiKaDiv reporting in Germany on Swiss custodians | zsis.ch
