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 |