Tax Leakage in Dual-Listed Shares: Understanding Withholding Risks

Dual-listed shares offer global investors better access to markets and increased trading flexibility. But they also carry hidden tax risks. One of the biggest is withholding tax leakage, which happens when the same dividend is taxed at different rates depending on the listing location. Many investors do not realise how much dividend tax they lose […]
G20 Pressure and WHT: Are Countries Quietly Raising Rates?

In the wake of sustained G20 scrutiny and shifting global tax dynamics, a growing concern has emerged among investors and tax professionals: are countries subtly increasing their withholding tax (WHT) rates without public disclosure? The push for greater fiscal transparency, combined with the rising need for revenue in post-pandemic economies, has led many jurisdictions to […]
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 […]
How to Handle Retroactive Tax Law Changes in Reclaim Applications

Introduction: The Challenge of Retroactive Tax Law Changes Retroactive tax law changes can create serious problems for international investors. Pension funds, asset managers, and other investors rely on stable rules when reclaiming withholding tax (WHT) on cross-border dividend income. When a country changes its tax laws and applies them to past events, it disrupts existing […]
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 […]
Withholding Tax and Global Sanctions: When Compliance Blocks Refunds

Introduction: A Shifting Global Landscape Withholding tax (WHT) recovery plays a key role in helping cross-border investors reduce tax drag on dividend income. But today’s geopolitical tensions are complicating the reclaim process. Sanctions, once a foreign policy tool, now impact how tax authorities and financial institutions handle WHT refunds. Investors must understand how global sanctions […]
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 […]