Will the OECD’s Pillar Two Global Tax Plan Change WHT Rules?

The Organisation for Economic Co-operation and Development’s (OECD) ambitious Pillar Two tax initiative is reshaping global corporate taxation. This global tax plan introduces a minimum corporate tax rate of 15% worldwide. It aims to reduce profit shifting and create a level playing field internationally. Multinational enterprises (MNEs) and investors now wonder if this significant tax […]
International WHT Compliance: Trump’s Impact on Global Tax

In international finance, few developments have a ripple effect like shifts in U.S. foreign policy. Now, with Donald Trump back in the White House in 2025, a renewed wave of uncertainty is sweeping through international withholding tax (WHT) compliance, dividend tax regimes, and withholding tax processes. For multinational investors, his return marks a continuation—and potential […]
Dutch Pension Funds and Withholding Tax Recovery Strategies

The Dutch pension system is strong, combining a pay-as-you-go state pension with capital-funded occupational pensions. Managing these funds requires handling dividend withholding tax (WHT) to maximise returns. This article explains WHT for Dutch pension funds and explores recovery strategies. Understanding Dividend Withholding Tax in the Netherlands In the Netherlands, resident corporations usually deduct a 15% […]
Major Win: US Businesses Can Recover Excess Dividend Tax from Italy

Breaking News: A Game-Changer for US Businesses Investing in Italy A recent ruling by the Italian Tax Court of First Instance in Pescara has set a powerful precedent, confirming that US corporations should be taxed at the same preferential 1.2% withholding tax rate as Italian and EU corporations—rather than the higher 5% or even 26% […]
Avoiding Common Pitfalls in WHT Reclaims After Recent Reforms

Introduction Withholding tax (WHT) is a critical consideration for investors receiving cross-border dividend income. While tax treaties often allow for reduced WHT rates or full exemptions, reclaiming excess tax withheld can be a complex and time-consuming process. Recent regulatory changes have further complicated WHT reclaims, requiring investors and financial institutions to stay informed and proactive. […]
Tax Relief Act: Withholding Tax Changes in the United States

Introduction Withholding tax (WHT) plays a critical role in the U.S. tax system, particularly concerning dividend tax. Investors, both domestic and foreign, are affected by changes in withholding tax policies. The recently enacted Tax Relief Act introduces key modifications that will influence how dividends are taxed. Understanding these changes is essential for ensuring compliance and […]
Withholding Tax Updates in Key Asian Markets for 2025

For savvy investors looking to tap into Asia’s dynamic markets in 2025, understanding the landscape of withholding tax is crucial. This tax is typically deducted from dividends, interest, and royalties before they reach foreign investors, ensuring that countries collect taxes on cross-border transactions efficiently. However, the WHT landscape varies widely across Asia, presenting both opportunities […]
WHT Refunds Got Easier: Investors Preparations 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 […]
Revolutionising Cross-Border Dividend Taxation: Implications of the CJEU’s Decision in C-601/23

In this article, we will provide an overview of spanish tax and what you need to know. On December 19, 2024, the Court of Justice of the European Union (CJEU) delivered a landmark ruling in Case C-601/23 concerning the taxation of dividends and the free movement of capital within the EU. The judgment struck down […]
Modernisation of German Withholding Tax Relief Legislation

In the complex world of international finance, withholding tax holds a significant place within Germany’s tax framework. This form of tax, deducted at source on income such as dividends, interest, and royalties, is a fundamental aspect of the German tax system, ensuring that taxes are collected efficiently from foreign and domestic entities alike. As the […]