Then, if the beneficial owner would like to use the reduced rate under GR-CH double tax treaty (10%), he would have to file a refund claim to the Swiss tax authorities. That claim would have to be accompanied by a certificate of tax residence issued by the Greek tax authorities. When requesting this certificate, the beneficial owner is effectively signalling to the Greek tax authorities the fact that he has earned or will earn income from a foreign source. Once he has filed the refund claim to the Swiss authorities, the Greek beneficial owner will be entitled to a refund for the difference between the anticipatory tax (500*0.35=175) and the maximum tax under the double tax treaty (500*0.10=50), which is 175-50=125. So, the actual tax burden in Switzerland after the application of the refund procedure is EUR 50. Now if the Greek domestic tax on the inbound interest income is 10%, it would in principle be levied on a gross basis, i.e. the tax base would be the full amount of interest income received (EUR 500). The Greek tax liability would be 500*0.10=50. However, under Art. 22 of the GR-CH Double tax treaty "Where a resident of Greece derives income which, in accordance with the provisions of this Convention may be taxed in Switzerland, Greece shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in Switzerland. Such deduction shall not, however, exceed that part of the Greek tax, as computed before the deduction is given, which is attributable to the income which may be taxed in Switzerland." The Greek beneficial owner would therefore be entitled to credit the EUR 50 levied in Switzerland against his tax liability in Greece, which is also EUR 50. Therefore, after the application of the credit, the Greek beneficial owner would not owe any Greek tax on that interest income.