WTO Disputes Over Dividend and Interest Taxation Rules

Global trade and tax are never entirely separate. Dividend tax and withholding tax (WHT) on interest have become friction points where fiscal policy collides with international trade rules. The World Trade Organization (WTO) was not designed to govern every detail of tax, but its rules still matter. Whenever tax measures distort trade, they can fall […]
Post-CJEU Changes in Poland’s Dividend WHT Recovery Rules

Poland’s dividend tax framework has shifted dramatically. A series of Court of Justice of the European Union (CJEU) rulings, new guidance from the Ministry of Finance, and evolving case law now dictate the rules of engagement. Asset managers, pension funds, insurers, and corporate treasuries who still rely on outdated methods risk unnecessary compliance exposure. This […]
The Impact of Domestic Court Decisions on Treaty-Based WHT Rights

Tax treaties promise predictable relief from dividend withholding tax (WHT). Reality is messier. National judges decide who truly owns the income, how anti-abuse rules apply, what evidence persuades, and whether deadlines cut you off. If you run money for funds, pensions, trusts or corporates, paperwork alone will not bank a refund. Instead, read the case […]
WHT Reclaims in BRICS Nations: An Emerging Power Bloc’s Approach

The dividend withholding tax (WHT) landscape across BRICS is not converging; it is fragmenting. Anyone banking on a neat, bloc-wide refund blueprint will be disappointed. Rates, treaty positions and reclaim mechanics diverge by market, and policy drift is real. If you run cross-border equity portfolios, treat heterogeneity as a design constraint, not an edge case. […]
Dividend Withholding Tax Refunds in Non-OECD Jurisdictions: A Growing Challenge

Introduction Dividend taxation has long created friction for cross-border investors. While OECD countries usually offer clearer refund systems, the same cannot be said for non-OECD markets. Investors looking to capture growth in Africa, Asia, Latin America, and the Middle East often face higher withholding tax (WHT) and weaker recovery processes. Dividend withholding tax refunds in […]
Future Trends in Global Withholding Tax Policy: What Investors Should Anticipate

Withholding tax (WHT) has always been one of the most contentious issues in cross-border investing. For global investors, dividend tax and interest tax leakages can erode returns if not properly managed. As markets grow more interconnected and governments pursue revenue aggressively, WHT policy is evolving at a pace that investors cannot afford to ignore. Understanding […]
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 […]
Investor Protection and WHT: How Courts Are Shaping Access to Treaty Benefits

In recent years, courts have stopped treating dividend WHT as a minor issue. They now view it as central to investor protection. When domestic laws over-tax non-residents compared with locals, judges intervene. They order refunds and reset expectations. For portfolio managers, these rulings now shape recovery yields and cash drag. Free movement and dividend tax: […]
Cross-Border Partnerships: Navigating Dividend WHT Obligations and Relief

Cross-border partnerships can be tax-efficient investment pipes, but they often sit at the awkward intersection of domestic transparency rules, treaty mechanics, and “beneficial owner” scrutiny. If you manage money through partnerships and you are still assuming dividend WHT is a back-office nuisance, you are underestimating the execution risk. Relief lives or dies on the details: […]
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 […]