Logitech 2013 Annual Report Download - page 132

Dividends
Under Swiss law, a corporation may only pay dividends upon a vote of its shareholders. This vote typically
follows the recommendation of the corporation’s board of directors. On September 5, 2012, Logitech’s shareholders
approved a cash dividend payment of CHF 125.7 million out of retained earnings to Logitech shareholders who
owned shares on September 17, 2012. Eligible shareholders were paid CHF 0.79 per share ($0.85 per share in U.S.
dollars), totaling $133.5 million in U.S. dollars on September 18, 2012. This dividend qualified as a distribution of
qualifying additional paid-in-capital and, as such, was not subject to Swiss Federal withholding tax.
Dividends paid and similar cash or in-kind distributions made by Logitech to a holder of Logitech shares
(including dividends or liquidation proceeds and stock dividends), other than distributions of qualifying additional
paid-in-capital if it is available under the current Swiss tax regime, are subject to a Swiss federal anticipatory tax at
a rate of 35%. The anticipatory tax must be withheld by Logitech from the gross distribution, and paid to the Swiss
Federal Tax Administration.
A Swiss resident holder and beneficial owner of Logitech shares may qualify for a full refund of the Swiss
anticipatory tax withheld from such dividends. A holder and beneficial owner of Logitech shares who is a non-
resident of Switzerland, but a resident of a country that maintains a double tax treaty with Switzerland, may qualify
for a full or partial refund of the Swiss anticipatory tax withheld from such dividends by virtue of the provisions
of the applicable treaty between Switzerland and the country of residence of the holder and beneficial owner of the
Logitech shares.
In accordance with the tax convention between the United States and the Swiss Confederation (‘‘Treaty’’),
a mechanism is provided whereby a United States resident (as determined under the Treaty), and United States
corporations, other than U.S. corporations having a ‘‘permanent establishment’’ or a fixed base, as defined in
the Treaty, in Switzerland, generally can obtain a refund of the Swiss anticipatory tax withheld from dividends in
respect of Logitech shares, to the extent that 15% of the gross dividend is withheld as final withholding tax (i.e.
20% of the gross dividend may generally be refunded). In specific cases, U.S. companies not having a ‘‘permanent
establishment’’ or a fixed base in Switzerland owning at least 10% of Logitech registered shares may receive a
refund of the Swiss anticipatory tax withheld from dividends to the extent it exceeds 5% of the gross dividend (i.e.
30% of the gross dividend may be refunded). To get the benefit of a refund, holders must beneficially own Logitech
shares at the time such dividend becomes due.
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