How to secure your ITIN – Smart planning for Non-US Investors
Why an ITIN Is Invaluable for Investors and Asset Managers As seasoned investors and fund managers, your engagement with U.S.-sourced income demands rigorous compliance. An Individual Taxpayer Identification Number (ITIN) is not optional—it is the foundational identifier the IRS requires of entities and individuals without a Social Security Number who nonetheless transact with U.S. tax […]
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 […]
A-Z of Withholding Tax Reclaims on Dividends
A • Administrative Support: Global Tax Recovery expertly handles the intricate paperwork and complex administrative tasks required to reclaim withholding taxes. This simplifies the process for investors. B • Beneficial Owner: The legal individual or entity entitled to dividend income, qualifying them to reclaim withheld taxes. C • Certificate of Tax Residency: An essential document […]
Unlocking Dividend Withholding Tax Reclaims: New US-Denmark Pension Fund Agreement
In a significant update for pension funds investing across borders, Denmark and the United States recently signed a Competent Authority Arrangement (CAA) that clarifies the definition of “pension fund” under the existing Double Taxation Agreement (DTA). This clarification significantly impacts withholding tax reclaims on dividends, providing substantial refund opportunities for pension entities. Background Effective from […]
Global Tax Transparency: Impact on WHT Recovery
In recent years, international taxation has changed significantly. One of the most important developments is the rise of global tax transparency initiatives. These measures aim to combat tax evasion and improve cross-border cooperation. They now strongly influence how investors, companies, and tax professionals approach withholding tax (WHT) recovery compliance. For dividend investors and institutional claimants, […]
How Economic Substance Rules Affect Withholding Tax Refund
As global tax authorities increase scrutiny of cross-border investment structures, economic substance rules have become crucial in determining eligibility for withholding tax (WHT) refunds. For international investors seeking relief from dividend tax burdens, understanding the connection between substance requirements and tax recovery is no longer optional. It is essential. At Global Tax Recovery, we have […]
Swiss Foundation Case Blows Open Germany’s “Phantom-Income” Tax Judgement
What just happened? Germany’s Federal Fiscal Court (BFH) has ruled that the escape hatch from § 15 AStG—the rule that taxes German residents on the undistributed income of a foreign family foundation—cannot be limited to EU/EEA structures. Cutting off non-EU foundations breaches the EU Treaty’s free-movement-of-capital guarantee. The court therefore reads the exemption as covering […]
NEPI Rockcastle Declares First Dividend of 2025 —Here’s How to Reclaim Your Withholding Tax
NEPI Rockcastle N.V. has capped off the 2024 financial year on a strong note by declaring a final dividend of 27.05 euro cents per share, maintaining a robust 90 percent payout ratio. While this underscores the company’s confidence and solid performance, how much shareholders actually pocket depends largely on one key factor: tax treatment. Capital […]
How Governments Use WHT to Counter BEPS
In recent years, the issue of tax base erosion and profit shifting (BEPS) has captured the attention of governments worldwide. Multinational corporations, through complex tax planning strategies, have been able to shift profits to low-tax jurisdictions. This has resulted in the eroding of the tax bases of countries where economic activity genuinely takes place. To […]
Digital Taxation and Withholding Tax: Are Higher Rates Coming?
In recent years, global tax policy has shifted dramatically. Digital taxation has become a priority for many governments. As the digital economy grows at an astonishing pace, countries are introducing Digital Services Taxes (DST) to capture revenue from technology giants and digital businesses operating across borders. This development raises a crucial question for international investors: […]