In a relief at source regime, the shareholder can be taxed at the lower treaty rate when the dividend is distributed if he/she has provided the necessary paperwork to the tax authority or local agent prior to pay date.

For example, say a U.S. investor is invested in Nestle, a Swiss company. The statutory withholding rate is 35%. If the investor provides documentation to the Swiss Tax Authority prior to dividend pay date, the investor can be withheld at the 15% treaty rate. On a $100 dividend, this means the investor would receive $85 on pay date rather than $65.