CJEU Strikes Down Poland’s External-Management WHT Exemption Requirement
On 27 February 2025, the Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑18/23, ruling that Poland’s Corporate Income Tax (CIT) exemption—limited to externally managed non-resident investment funds—violates Article 63(1) of the Treaty on the Functioning of the European Union (TFEU). This decision unlocks refund opportunities for internally managed funds […]
How the Global Forum Boosts Transparency and Tax Cooperation
In today’s economy, tax compliance and cooperation are more important than ever. One of the most influential initiatives shaping international tax policy is the Global Forum on Transparency and Exchange of Information for Tax Purposes. Established by the OECD, the Global Forum plays a key role in promoting transparency, tackling tax evasion, and improving cross-border […]
The OECD’s Tax Certainty Agenda: Impact on WHT Reclaims
In today’s increasingly complex global tax environment, tax certainty is more crucial than ever. For international investors, navigating withholding tax (WHT) on cross-border dividend payments has long been frustrating and risky. The Organisation for Economic Co-operation and Development (OECD) has recognised these challenges. Through its Tax Certainty Agenda, it aims to bring clarity, predictability, and […]
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 […]