Emerging Africa: Treaty Upgrades vs. Administrative Drag
Treaty reform is moving faster than treaty delivery Across emerging Africa, treaty policy has moved forward. Several jurisdictions have updated treaty networks, adopted Base Erosion and Profit Shifting standards, or absorbed anti-abuse changes through the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, commonly called the Multilateral Instrument. […]
Africa 2026 Watchlist: Morocco, Egypt, Kenya, Nigeria WHT Developments
Africa’s 2026 withholding tax (WHT) landscape is becoming a year of tighter administration, sharper classification rules, and more demanding documentation standards. Across Morocco, Egypt, Kenya, and Nigeria, WHT risk is moving deeper into treaty access, source rules, digital enforcement, and payment characterisation. For cross-border investors, that changes the control framework. The real issue is no […]
Germany §50d(3): Passing Anti-Treaty-Shopping Tests
Why German anti-treaty-shopping now drives refund outcomes German anti-treaty-shopping now sits near the centre of German withholding tax (WHT) recovery risk. That was not always the case. In the past, many claimants focused on treaty wording, residence certificates, and form completion. Today, that approach is too thin. Germany now asks a harder question. It asks […]
Common Mistakes in Swiss WHT Claims (And How to Avoid Them)
Swiss withholding tax claims are not hard to understand. They are hard to execute well. Switzerland imposes a 35% withholding tax on dividend income and certain other returns. Foreign investors can often recover part of that tax under an applicable double taxation agreement. Even so, many claims fail long before the refund stage. The problems […]
Form 90 Explained: Documentation for Swiss WHT Claims
Why this Swiss Form 90 guide matters A proper Swiss Form 90 guide starts with one key point. Form 90 does not cover every foreign investor who files a Swiss reclaim. It applies to claimants who are residents in Spain and who seek a refund of Swiss anticipatory tax on Swiss-source dividends and interest. The […]
Switzerland e-Refund Portal: Step-by-Step Filing Guide
Introduction: Why the Switzerland e-Refund System Matters Cross-border investors holding Swiss equities often face one unavoidable reality: Switzerland applies one of the highest statutory dividend withholding tax rates in developed markets. Under Swiss law, dividends paid by Swiss companies are typically subject to 35% withholding tax at source. In theory, tax treaties allow many foreign […]
Switzerland’s 35% WHT: Complete Recovery Guide for Foreign Investors
Why Swiss 35% WHT recovery matters Swiss 35% WHT recovery matters because the tax takes cash off the table on day one. Switzerland applies anticipatory tax at 35% to investment income such as dividends, and foreign investors usually need to recover any excess through a treaty-based refund process. That means the commercial issue is not […]
Coordinating WHT Recovery with Your Existing Tax Advisors
Why a wealth manager should treat WHT coordination as an operating model issue For a wealth manager, withholding tax (WHT) recovery usually breaks down for a simple reason: the tax work is technically correct, but the operating model is fragmented. The investment team holds the transaction data, the custodian controls parts of the payment chain, […]
Family Office Guide to Cross-Border Dividend Taxation
Why family office dividend tax deserves board-level attention Family office dividend tax is often treated as an administrative detail. That framing creates avoidable cash leakage. Cross-border dividend income usually moves through several layers, including the issuer market, local paying agent, custodian chain, portfolio structure, and tax reporting process. Even a well-run family office can lose […]
Why High-Net-Worth Investors Leave Money on the Table: The WHT Gap
The problem most wealthy investors do not see until it hurts High-net-worth individual (HNWI) wealth is rising again, and private capital is entering a long transfer cycle. Capgemini’s World Wealth Report 2025 says global HNWI wealth grew by 4.2% in 2024 and the HNWI population grew by 2.6%, while $83.5 trillion is expected to pass […]