Copio/pego la respuesta de Vaneck. Mencionan que al tratarse de una “Fiscale BeleggingsInstelling” pueden reclamar la retención USA y te convierten la retención USA en una retención NL (15%) que en España puedes deducirte en la declaración de la renta indicándola como doble imposición de la manera habitual.
Many thanks for reaching out.
As you may have seen from the fund documentation the TDIV ETF is domiciled in the Netherlands. For US dividends in your example the ETF receives 85% of the dividend. Due to the fiscal status of Fiscal Investment Institution (Fiscale BeleggingsInstelling) of the ETF there is also a claim on the 15% US Dividend tax which was withheld at source. When the ETF distributes its income on a quarterly basis it pays the 85% net and on top of that the 15% claim of that withheld dividend. The US dividend tax in that case was converted to a Dutch offsetable dividend tax which can be reclaimed or offset by certain investors. The example is for a US dividend, but the same principle is applicable for most other countries the ETF invests in.
If you look at an ETF domiciled in Ireland for example the ETF would also receive 85% of the US dividend but cannot pass on that 15% claim on the US tax. Therefore, it will distribute 85% only to investors when it pays out a dividend and the 15% is lost at the ETF level. As an Irish ETF does not have to withhold tax on its distribution it may seem you receive 100%, but this is actually only 85% due to the withholding taking place at the ETF level. Reclaimable taxes that may apply to dividends from countries such as Switzerland for example will be reclaimed by the custodian of the ETF and are therefore included in the price of the ETF.
So, under the assumption that you would be able to reclaim or offset the Dutch withholding tax withheld on the ETF to you, you would receive close to 100% of all the dividends paid to the ETF as those claims are equal to the 15% Dutch withholding tax.
I hope this clarifies the treatment. Do not hesitate to contact us in case you have further questions.