Swiss tax

[Nonimous]

Greetings

My client received a huge Swiss dividend paid out in June 2017, The Swiss collected 35% tax, and we got some of that refunded so that in effect, 15% was paid to Switzerland. The refund did not arrive until September 18 because the Swiss authorities mislaid the paperwork

Client is now complaining bitterly that I converted the entire dividend at the exchange rate in June 17 when in fact she received 65% of her dividend in June 17 and the other 20% in September 2018 and the exchange rates altered

I don't think there is anything I can do about this. Or is there? All I could think of was having her pay the remittance basis charge instead and I do not think she would be happy with that.

[AGoodman]

Absent a good argument (and I can't think of any) the default position must be the exchange rate on the date the dividend was paid (i.e. June).