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 […]
Switzerland’s WHT Refund Requirements: 2025 Filing Protocols Explained
Switzerland remains a popular jurisdiction for global investors, offering economic stability, a reliable financial system, and a wide double taxation treaty (DTT) network. However, foreign investors earning dividend income from Swiss companies must navigate a complex withholding tax (WHT) system. In 2025, the Swiss Federal Tax Administration (FTA) updated its WHT refund process. These changes […]
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 […]
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 […]
When Relief-at-Source Fails: Recovering Overpaid Withholding Tax
Withholding tax on dividends remains a major challenge for institutional investors and cross-border asset managers. Relief-at-source mechanisms were designed to simplify the process by applying reduced treaty rates at the time of payment. In practice, however, these mechanisms often fail. Overpayments of withholding tax are common, creating costly and time-consuming obstacles for investors. When the […]
How the Global Minimum Tax May Complicate WHT Reclaim Rights
The global minimum tax marks a major shift in international tax policy. Spearheaded by the OECD and G20, it introduces a 15% minimum effective corporate tax rate for large multinational corporations. While designed to create fairer taxation and reduce profit shifting, the rules may have unintended effects. One of the most significant is the impact […]
OECD’s Blockchain-Based WHT Pilot: What Investors Must Know
The Organisation for Economic Co-operation and Development (OECD) is launching a new initiative in 2025 that could reshape international tax compliance. The pilot project uses blockchain technology to modernise withholding tax (WHT) systems, especially for cross-border dividend tax recovery. For institutional investors, this development may simplify reclaim procedures and enhance transparency in global tax administration. […]