Emerging Trends in African Tax Treaties: Dividend WHT Provisions Under Review
African tax treaties are in flux. Governments are rewriting terms to capture more revenue from cross-border payments, with special focus on withholding tax on dividends. For investors, funds, and corporates, this shift means past treaty assumptions no longer hold. ATAF’s New Model and Dividend WHT Focus The African Tax Administration Forum (ATAF) is updating its […]
Profit Shifting Rules and Their WHT Implications
Profit shifting rules have moved from academic talking points to boardroom risks. Tax authorities are sharpening their tools, and dividend tax together with withholding tax (WHT) is now front-line territory. Funds, pension schemes, and corporates that route dividends, interest, and royalties through multi-jurisdictional structures are realising today’s tests go far beyond paperwork. Substance, purpose, and […]
ASEAN’s WHT Regime: Opportunities & Pitfalls
Investors are drawn to ASEAN for its growth, yield, and diversification. What they do not welcome is friction. Dividend tax and withholding tax (WHT) rules across the region remain fragmented, creating a patchwork of rates, relief-at-source requirements, treaty paperwork, and anti-abuse tests. For anyone managing cross-border dividend flows, this is where returns are quietly eroded. […]
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 […]
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 […]
When AML Rules Block WHT Reclaims: A Hidden Compliance Risk
Withholding tax reclaims should be a straightforward process: dividend tax withheld is reclaimed through treaty relief. In practice, anti-money-laundering (AML) controls often derail valid claims. Banks, custodians and fiscal agents take AML exposure seriously, and their red flags can freeze the process. As a result, WHT reclaims are rejected, delayed, or abandoned. This article examines […]
WTO Crises and Their Ripple Effect on WHT
Global trade never exists in isolation. Each disruption in international commerce sends waves through capital markets, investor confidence, and taxation. One overlooked consequence of World Trade Organization (WTO) crises is the effect on withholding tax (WHT), especially in relation to dividend tax regimes. When WTO processes stall or disputes escalate, the impact often reaches investors […]