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 […]
G20 Pressure and WHT: Are Countries Quietly Raising Rates?

In the wake of sustained G20 scrutiny and shifting global tax dynamics, a growing concern has emerged among investors and tax professionals: are countries subtly increasing their withholding tax (WHT) rates without public disclosure? The push for greater fiscal transparency, combined with the rising need for revenue in post-pandemic economies, has led many jurisdictions to […]
How Anti-Abuse Clauses Are Changing the WHT Reclaim Landscape

Introduction: Rising Barriers in WHT Reclaims Withholding tax (WHT) on dividends continues to challenge cross-border investors. Pension funds, asset managers and institutions regularly try to recover excess WHT on foreign-sourced dividends. However, a sharp rise in anti-abuse clauses has made the reclaim process more difficult. These clauses aim to stop tax treaty abuse and aggressive […]
When to Outsource WHT Reclaim Processes

Knowing the Right Time to Streamline Withholding Tax Recovery For global investors, pension funds, and asset managers, withholding tax (WHT) reclaims can become an operational burden. While recovering dividend tax withheld at source helps boost net returns, the process is often complex. Each jurisdiction imposes different documentation rules, language requirements, and filing standards. At a […]
The Rise of Bilateral Tax Disputes: What This Means for WHT Refunds

Bilateral tax disputes are becoming more common and more disruptive. Countries are clashing over tax treaty interpretations, and this friction is now affecting global investment flows. Investors, pension funds, and asset managers increasingly struggle to recover withholding tax (WHT) on dividends, interest, and royalties. This rise in disputes is reshaping the way investors claim WHT […]
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 […]
Withholding Tax and Global Sanctions: When Compliance Blocks Refunds

Introduction: A Shifting Global Landscape Withholding tax (WHT) recovery plays a key role in helping cross-border investors reduce tax drag on dividend income. But today’s geopolitical tensions are complicating the reclaim process. Sanctions, once a foreign policy tool, now impact how tax authorities and financial institutions handle WHT refunds. Investors must understand how global sanctions […]
Passive Income Streams and WHT: What Institutional Investors Must Know

Maximising Tax Efficiency in a Complex Withholding Tax Landscape As global markets evolve, passive income streams have become more attractive to institutional investors seeking long-term, stable returns. These income sources—especially dividends and interest—offer steady cash flow without constant portfolio rebalancing. However, when these streams cross borders, they are often subject to withholding tax (WHT). This […]
The OECD’s STTR and Its Effect on Withholding Tax Rates

Introduction: A New Frontier in Withholding Tax Regulation In recent years, international tax policy has undergone significant changes driven by the Organisation for Economic Co-operation and Development (OECD). Among the most notable developments is the Subject to Tax Rule (STTR), introduced under Pillar Two of the OECD’s global tax framework. While initially designed to prevent […]