ADR vs. GDR: Which Structure Minimises Withholding Tax?
Investors looking to diversify globally often turn to depositary receipts. These instruments offer exposure to foreign companies without the complications of direct overseas share ownership. Among the most common are American Depositary Receipts (ADRs) and Global Depositary Receipts (GDRs). While both structures serve a similar purpose, they differ in how they handle withholding tax (WHT) […]
WHT in the Gig Economy: When Freelancers Become Global Investors
The gig economy is expanding rapidly, and freelancers are embracing the flexibility and independence that come with self-employment. Many are now earning enough to invest in global markets. This growing class of international investors is financially independent and agile, but they frequently encounter tax-related challenges—particularly with withholding tax (WHT) on dividends. Freelancers and digital nomads […]
UK Developments in Principal Purpose Test and WHT Compliance
How Recent UK Shifts Impact Dividend Tax Recovery and Withholding Tax Planning The United Kingdom’s (UK) approach to withholding tax (WHT) compliance and treaty abuse prevention is undergoing significant change in 2025. The application of the Principal Purpose Test (PPT), introduced under the OECD’s Base Erosion and Profit Shifting (BEPS) Action 6 plan, has evolved […]
2025 EU Directive on WHT Reclaims: A Game-Changer?
Withholding tax (WHT) reclaims have long created difficulties for cross-border investors in the European Union. The current fragmented system causes delays, administrative complexity, and often leads to lost refunds—even when investors have a legal right to reclaim them. However, a major change is on the horizon. The European Commission has proposed a directive, due in […]
Dividend Tax Timing: Does the Payout Date or Ex-Dividend Date Matter for WHT?
In the world of international investing, timing matters—especially when it comes to dividend taxation. Many investors focus on dividend yields, tax treaties, and cross-border compliance, yet often overlook one crucial detail: whether the ex-dividend date or payout date triggers withholding tax (WHT). Knowing which date counts can improve your dividend tax recovery strategy, reduce tax […]
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 […]
Digitising Your Tax Documents: What You’ll Need for 2025 Claims
As global tax regulations grow more complex, investors and financial professionals are turning to digitisation to simplify tax compliance and maximise recovery. For 2025 claims, especially those involving dividend tax and withholding tax (WHT), having your tax documents in a digital and organised format is essential. This article explains why digitising your tax records matters, […]
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 […]
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, […]
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 […]