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 […]
How ASEAN’s Growing Tax Network Affects Dividend Reclaims
As the Association of Southeast Asian Nations (ASEAN) develops its regional tax framework, the implications for dividend reclaims and withholding tax (WHT) compliance are becoming more significant. For foreign investors eyeing the region’s vibrant capital markets—from Singapore and Malaysia to Thailand, Indonesia and Vietnam—understanding the nuances of ASEAN’s evolving tax landscape is vital for managing […]
Navigating Canada’s 2025 CRA Guidelines for WHT Relief
Canada remains an attractive destination for foreign investors due to its strong economy and transparent regulatory environment. However, withholding tax (WHT) continues to affect how non-residents manage their Canadian-source income—particularly dividends. In 2025, the Canada Revenue Agency (CRA) introduced new guidelines that change how international investors can claim WHT relief. These updates aim to tighten […]
Time Limits for WHT Reclaims in 2025: Country-by-Country Guide
Navigating the world of withholding tax (WHT) reclaims can feel overwhelming, especially when each country enforces strict deadlines for refunds. In 2025, investors, fund managers and tax professionals need to understand the unique time limits for recovering overpaid dividend tax across jurisdictions. Missing a filing deadline often means forfeiting potential refunds. This guide breaks down […]
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 […]
Canada’s Tax Treaty Network: Maximising Withholding Tax Refunds
Canada’s tax treaty network helps foreign investors reduce or eliminate withholding tax (WHT) on dividends and maximise their withholding tax refunds. Investors who understand and use these treaties can keep more of their earnings. This article explains Canada’s tax treaties, the standard withholding tax rates, and how investors can reclaim excess tax. Understanding Canada’s Withholding […]
Navigating Tax Compliance Amid Rising U.S. Protectionism
As global economic tensions rise, U.S. protectionism is creating new challenges for international investors. Trade barriers, reshoring policies, and restrictive tax reforms are reshaping the financial landscape, especially for cross-border investments. Investors and institutions worldwide must now understand how these shifts affect withholding tax (WHT), dividend tax obligations, and tax compliance. At Global Tax Recovery, […]
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 […]
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 […]
Tax Treaty Abuse: How Anti-Avoidance Rules Impact WHT Refunds
In recent years, tax authorities around the globe have intensified their scrutiny of cross-border investments, particularly in relation to withholding tax (WHT) refunds. One of the most significant developments has been the global crackdown on tax treaty abuse. Designed to curb aggressive tax planning, these anti-avoidance measures are reshaping how investors and institutions approach dividend […]