How Economic Substance Rules Affect Withholding Tax Refund
As global tax authorities increase scrutiny of cross-border investment structures, economic substance rules have become crucial in determining eligibility for withholding tax (WHT) refunds. For international investors seeking relief from dividend tax burdens, understanding the connection between substance requirements and tax recovery is no longer optional. It is essential. At Global Tax Recovery, we have […]
OECD Global Minimum Tax: Impact on Swiss WHT Recovery
The global tax landscape is changing rapidly, creating significant implications for investors and international businesses. One of the most important developments is the OECD’s Global Minimum Tax initiative, also called Pillar Two of the BEPS (Base Erosion and Profit Shifting) project. If you invest in Switzerland, you must understand how this policy shift affects Swiss […]
US – France Tax Dispute: Impact on WHT Refunds
The ongoing tax dispute between the United States and France has become a serious concern for investors. This is especially true for those trying to recover withholding tax (WHT) on dividends. French investors who rely on US dividend income are increasingly anxious about how these tensions affect their ability to claim back taxes. As both […]
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 […]
Digital Taxation and Withholding Tax: Are Higher Rates Coming?
In recent years, global tax policy has shifted dramatically. Digital taxation has become a priority for many governments. As the digital economy grows at an astonishing pace, countries are introducing Digital Services Taxes (DST) to capture revenue from technology giants and digital businesses operating across borders. This development raises a crucial question for international investors: […]
Are Digital Currencies Subject to Withholding Tax?
Digital currencies, commonly referred to as cryptocurrencies, have revolutionised the financial landscape by introducing decentralised and borderless means of value transfer. As their adoption grows, taxation becomes more complex. One area that often raises questions is whether withholding tax (WHT) applies to digital currencies, particularly in relation to dividend tax. This article explores whether digital […]
Withholding Tax Refunds Just Got Easier: How Investors Can Prepare for the EU’s FASTER Directive
Background On 14 May 2024, the EU Council agreed on the FASTER Directive (Faster and Safer Tax Relief of Excess Withholding Taxes), a measure designed to simplify and accelerate withholding tax refunds within the European Union. The directive introduces digitised and modern procedures, which will alleviate administrative burdens on investors and tax authorities alike. Why […]
Swiss Withholding Tax Policy: An In-Depth Guide
Switzerland, renowned for its financial prowess and stability, also boasts a unique and complex withholding tax policy. Understanding Swiss withholding tax policy is crucial for investors, pension funds, and financial professionals aiming to optimise their tax strategies. This article delves into the intricacies of Swiss withholding tax, focusing on dividend tax. Understanding Swiss Withholding Tax […]
Navigating International Dividend Tax
Navigating the complex world of international dividend tax can be challenging for investors. With varying rates, regulations, and processes across different jurisdictions, understanding how to manage and reclaim withholding tax (WHT) on dividends is crucial. This article aims to provide a comprehensive guide to navigating international dividend tax, focusing on key aspects such as withholding […]