The OECD’s STTR and Its Effect on Withholding Tax Rates
Introduction: A New Frontier in Withholding Tax Regulation In recent years, international tax policy has undergone significant changes driven by the Organisation for Economic Co-operation and Development (OECD). Among the most notable developments is the Subject to Tax Rule (STTR), introduced under Pillar Two of the OECD’s global tax framework. While initially designed to prevent […]
When Relief-at-Source Fails: Recovering Overpaid Withholding Tax
Withholding tax on dividends remains a major challenge for institutional investors and cross-border asset managers. Relief-at-source mechanisms were designed to simplify the process by applying reduced treaty rates at the time of payment. In practice, however, these mechanisms often fail. Overpayments of withholding tax are common, creating costly and time-consuming obstacles for investors. When the […]
How the Global Minimum Tax May Complicate WHT Reclaim Rights
The global minimum tax marks a major shift in international tax policy. Spearheaded by the OECD and G20, it introduces a 15% minimum effective corporate tax rate for large multinational corporations. While designed to create fairer taxation and reduce profit shifting, the rules may have unintended effects. One of the most significant is the impact […]
OECD’s Blockchain-Based WHT Pilot: What Investors Must Know
The Organisation for Economic Co-operation and Development (OECD) is launching a new initiative in 2025 that could reshape international tax compliance. The pilot project uses blockchain technology to modernise withholding tax (WHT) systems, especially for cross-border dividend tax recovery. For institutional investors, this development may simplify reclaim procedures and enhance transparency in global tax administration. […]
Withholding Tax in Germany: 2025 Refund Risks and Policy Updates
Introduction: Understanding Withholding Tax (WHT) in Germany Withholding tax (WHT) on dividends continues to challenge international investors in German equities. In 2025, several policy changes are shaping the WHT refund process. These changes create both risks and opportunities for investors. Foreign pension funds, institutional asset managers, and cross-border investors must stay informed. Understanding these updates […]
Dividend Tax and SPAC Investments: A Withholding Perspective
In recent years, Special Purpose Acquisition Companies (SPACs) have re-emerged as a favoured investment vehicle in global capital markets. Their unique structure allows private companies to go public through a reverse merger, bypassing the traditional initial public offering process. While investors are often drawn to the potential for quick returns, there is a lesser-known but […]
OECD Treaty Abuse Rules: What 2025 Updates Mean for WHT Recovery
In 2025, global investors and asset managers must prepare for significant changes in how tax authorities assess claims under tax treaties. The Organisation for Economic Co-operation and Development (OECD) has updated its rules to target treaty abuse more aggressively. These changes will have a major impact on withholding tax (WHT) recovery, particularly for dividend tax […]
UK Developments in Principal Purpose Test and WHT Compliance
How Recent UK Shifts Impact Dividend Tax Recovery and Withholding Tax Planning The United Kingdom’s (UK) approach to withholding tax (WHT) compliance and treaty abuse prevention is undergoing significant change in 2025. The application of the Principal Purpose Test (PPT), introduced under the OECD’s Base Erosion and Profit Shifting (BEPS) Action 6 plan, has evolved […]
The Great Treaty Renegotiation: 2025 Global Tax Networks
In 2025, the global tax landscape is changing rapidly. An unprecedented wave of treaty renegotiations is underway. Countries are reviewing their bilateral tax treaties due to rising fiscal pressure, global reforms, and growing cross-border investment. These developments are reshaping dividend tax regimes, withholding tax (WHT) processes, and international tax networks. For investors and fund managers, […]
Legal Strategies: Can Investors Challenge Anti-Abuse-Based WHT Denials?
Withholding tax (WHT) reclaim procedures have become increasingly complex for cross-border investors. Anti-abuse provisions—designed to stop treaty shopping and artificial structures—now drive many dividend tax reclaim denials. In 2025, regulatory scrutiny is rising, and legal interpretations continue to evolve. As a result, many investors are asking if they can successfully challenge such denials. This article […]