Emerging Trends in African Tax Treaties: Dividend WHT Provisions Under Review

Emerging Trends in African Tax Treaties: Dividend WHT Provisions Under Review

African tax treaties are in flux. Governments are rewriting terms to capture more revenue from cross-border payments, with special focus on withholding tax on dividends. For investors, funds, and corporates, this shift means past treaty assumptions no longer hold. ATAF’s New Model and Dividend WHT Focus The African Tax Administration Forum (ATAF) is updating its […]

When AML Rules Block WHT Reclaims: A Hidden Compliance Risk

Withholding tax reclaims should be a straightforward process: dividend tax withheld is reclaimed through treaty relief. In practice, anti-money-laundering (AML) controls often derail valid claims. Banks, custodians and fiscal agents take AML exposure seriously, and their red flags can freeze the process. As a result, WHT reclaims are rejected, delayed, or abandoned. This article examines […]

U.S. Withholding Tax for Foreign Investors: What’s New in 2025

Foreign investors continue to view the United States as a profitable destination for portfolio investment, particularly for dividend-generating assets. However, 2025 has brought several changes to the U.S. withholding tax (WHT) system. For institutional investors, pension funds, and asset managers based outside the U.S., staying updated is vital. These changes affect compliance and the ability […]

Tax Leakage in Dual-Listed Shares: Understanding Withholding Risks

Dual-listed shares offer global investors better access to markets and increased trading flexibility. But they also carry hidden tax risks. One of the biggest is withholding tax leakage, which happens when the same dividend is taxed at different rates depending on the listing location. Many investors do not realise how much dividend tax they lose […]

South Africa’s WHT on Dividends: Reclaim Tips for Foreign Institutions

Understanding WHT on Dividends in South Africa South Africa’s dividend tax regime directly affects the net returns of foreign institutional investors. A 20% withholding tax (WHT) applies to dividends paid by South African companies to non-resident shareholders. Although tax treaties may reduce this rate, many investors face difficulties reclaiming overpaid amounts. The process is especially […]

Dividend Tax and SPAC Investments: A Withholding Perspective

In recent years, Special Purpose Acquisition Companies (SPACs) have re-emerged as a favoured investment vehicle in global capital markets. Their unique structure allows private companies to go public through a reverse merger, bypassing the traditional initial public offering process. While investors are often drawn to the potential for quick returns, there is a lesser-known but […]

Withholding Tax in Frontier Markets: Risks and Recovery Options

As investors seek higher returns in fast-growing regions, frontier markets have become more attractive. These economies—less advanced than emerging markets but more accessible than the least developed nations—offer strong dividend yields and capital growth potential. However, they also pose significant risks, particularly in the form of complex tax regimes. One of the most pressing issues […]

Why Custodians Are Under Pressure to Prove Tax Compliance

In today’s financial environment, custodians are under growing pressure to prove tax compliance—particularly regarding dividend tax and withholding tax (WHT). Regulators around the world are enforcing stricter rules and demanding transparency. As a result, custodians now carry greater responsibility for tax-related matters. Their role extends beyond safeguarding assets to ensuring compliance with complex global tax […]

Digitising Your Tax Documents: What You’ll Need for 2025 Claims

As global tax regulations grow more complex, investors and financial professionals are turning to digitisation to simplify tax compliance and maximise recovery. For 2025 claims, especially those involving dividend tax and withholding tax (WHT), having your tax documents in a digital and organised format is essential. This article explains why digitising your tax records matters, […]

The Future of WHT Relief-at-Source Mechanisms: Can They Replace Reclaim Processes?

As global markets connect more closely, the challenges around withholding tax (WHT) on cross-border dividends continue to increase. Investors and financial institutions face the constant task of dealing with double taxation, delayed refunds, and the heavy paperwork of reclaiming WHT on dividend income. WHT relief-at-source mechanisms have emerged as a promising alternative. But can these […]