Navigating WHT Reclaims in Countries with No Double Tax Treaty
In cross-border investments, understanding dividend tax and withholding tax (WHT) reclaims is essential. The challenge grows when no double tax treaty exists between your country of residence and the source country. Without treaty protection, reclaiming over-withheld WHT becomes more complex. This article explains the main obstacles and outlines strategies to improve recovery prospects in non-treaty […]
Pension Fund Eligibility for Treaty-Based WHT Relief: Key Global Trends
Dividend tax continues to erode net investment returns for cross-border pension portfolios. In principle, treaty-based WHT relief should mitigate that erosion. However, eligibility tests, anti-abuse provisions, and fragmented operational practices often cause avoidable losses. This article explores the direction of travel in global policy, identifies key regional trends, and highlights the operational steps pension funds […]
Multi-Tier Holding Companies: Reducing WHT While Staying Compliant
Multi-tier holding companies can lower withholding tax (WHT) costs, but only when they show real business purpose. Tax offices now test dividend tax structures more aggressively. They look for substance, not just paperwork. If your holding chain exists only to reduce WHT, it risks challenge. To succeed, companies must design structures that reflect genuine commercial […]
OECD WHT Policy Harmonisation: Tollbooth or Gateway?
The debate on withholding tax is now practical, not theoretical. Cross-border dividend tax and interest flows sit at the centre of reforms led by the OECD and the EU. Both bodies are pushing for unified models that aim to cut friction while tightening compliance. The challenge for investors, funds and custodians is direct: is OECD-led […]
Unlocking WHT Reclaims Under the New China–Italy DTA: 2026 Changes?
The new China–Italy double tax agreement (DTA) entered into force on 19 February 2025. From 1 January 2026, it applies to withholding taxes (WHT). This agreement reshapes dividend tax and reclaim strategies by resetting rates, eligibility tests and processes. For investors between the two countries, the changes are material and require proactive planning. Dividend: From […]
2025 Withholding Tax Reform Roundup: What’s Changing and How to Prepare
Dividend withholding tax rules are changing across multiple jurisdictions in 2025. For funds and corporates receiving cross-border dividends, the cost of staying compliant is rising. Relief at source, dividend tax reclaims, and documentation are no longer optional back-office chores. They are now strategic functions. This roundup highlights the key reforms and shows how to prepare […]
Why Multi-Layer Holding Structures Are Increasingly Scrutinised by Tax Authorities
Tax authorities no longer accept at face value that complex corporate chains exist mainly for commercial reasons. They now scrutinise multi-layer holding structures because investors often use them to exploit differences in dividend withholding tax (WHT) across borders. Global enforcement has shifted: data-sharing makes ownership transparent, anti-abuse rules provide enforcement tools, and courts interpret beneficial […]
Investor Rights in Withholding Tax Disputes: Litigation or Arbitration?
Cross-border investing creates strong dividend flows but also brings an unwelcome burden: withholding tax. When tax authorities collect more than they should, investors must decide how to fight back. The central question is whether to resolve withholding tax (WHT) disputes through litigation, arbitration, or administrative relief. This decision dictates how much time, cost, and certainty […]
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 […]
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 […]