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Foreign Dividend Withholding Tax for Canadian Investors: Country-by-Country Guide

Updated

Foreign dividends from outside the United States face their own withholding rules. Where you invest — and which account you hold them in — determines how much of each dividend you keep.

Withholding tax rates by country for Canadian investors

Country Domestic WHT rate Treaty rate (Canada) TFSA recovery RRSP recovery Non-reg recovery
United States 30% 15% (0% in RRSP) None Full (0%) Full via T2209
United Kingdom 0% 0% N/A N/A N/A
Germany 26.375% 15% None Partial (15% still applies) Full via T2209
France 30% 15% None Partial (15% still applies) Full via T2209
Switzerland 35% 15% None Partial (15% still applies) Full via T2209
Netherlands 15% 15% None Partial Full via T2209
Japan 20.315% 15% None Partial (15% still applies) Full via T2209
Australia (unfranked) 30% 15% None Partial Full via T2209
Australia (franked) 0% 0% N/A N/A N/A
Canada N/A N/A N/A N/A Dividend tax credit
Singapore 0% 0% N/A N/A N/A
Hong Kong 0% 0% N/A N/A N/A
China 10% 10% None Partial Full via T2209
India 20% 15–20% None Partial Full via T2209
South Korea 22% 15% None Partial Full via T2209

Key insight: only the US-Canada treaty fully exempts Canadian registered accounts

The Canada-US treaty Article XXI(2) has a specific registered-plan pension exemption covering RRSP and RRIF. Most other Canadian tax treaties do not include an equivalent registered-plan exemption. As a result:

  • US dividends in RRSP: 0% withholding
  • European dividends in RRSP: typically still 15% withheld (cannot recover inside registered account)
  • UK dividends in any account: 0% (no withholding to discuss)

This means the RRSP preference for avoiding withholding applies uniquely to US dividends. For European and Asian dividends, the non-registered account (where T2209 recovery is available) may actually be preferable to RRSP.


Embedded withholding drag in international ETFs (approximate)

ETF type Typical embedded drag (TFSA) Typical embedded drag (RRSP) Typical embedded drag (Non-reg)
US equity (VFV) ~0.17–0.20% ~0.17–0.20% ~0.17% (unrecoverable fund portion)
International developed (VIU, XEF) ~0.25–0.40% ~0.20–0.35% ~0.25–0.40% (partial T3 recovery)
Emerging markets (XEC, VEE) ~0.30–0.60% ~0.25–0.50% ~0.30–0.60% (partial T3 recovery)
Canadian equity (XIC, VCN) 0% 0% 0%

Asset location summary: where to hold what

Asset class Best account Worst account Reason
US equity ETF RRSP TFSA Treaty exempts RRSP; TFSA has permanent 15% loss
UK stocks/ETF Any 0% withholding everywhere
European equity ETF Non-reg TFSA T2209 recovery in non-reg; no recovery in TFSA
International developed (VIU) Non-reg or RRSP TFSA Partial T2209 in non-reg; no recovery in TFSA
Emerging markets Non-reg TFSA Same as above
Canadian equity TFSA first No withholding, maximum tax-sheltered growth