Anti-Treaty-Shopping Rules: Global Overview and Compliance
Cross-border investors have spent decades relying on tax treaties to reduce withholding tax on dividends, interest, and royalties. That landscape has changed materially. Governments now scrutinise treaty claims far more aggressively, particularly where structures appear designed primarily to obtain treaty benefits rather than support genuine commercial activity. As a result, anti-treaty shopping has moved from […]
Common Documentation Failures and How to Prevent Them
Withholding tax (WHT) recovery often breaks down before a tax authority issues a formal rejection. Inconsistent claimant names, unclear ownership, missing credit advices, expired residence certificates, and defective forms are common WHT documentation errors that can delay or derail valid reclaims. These issues are becoming harder to defend as tax authorities and intermediaries move toward […]
Chain of Custody Documentation for Complex Structures
Why complex structure WHT documentation now matters more For complex holding structures, withholding tax (WHT) recovery often fails long before a tax authority reaches the treaty analysis. The weak point is usually the evidence trail. If the claimant cannot connect the legal owner, beneficial owner, custody account, income event and tax suffered into one coherent […]