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, […]
How Anti-Abuse Clauses Are Denying Dividend Tax Reclaims

Cross-border investors face increasing difficulty reclaiming dividend tax due to anti-abuse clauses in tax treaties. These provisions were designed to stop treaty shopping and aggressive tax planning. However, tax authorities now use them to reject legitimate withholding tax (WHT) refund claims. As more jurisdictions demand strict compliance with substance and ownership rules, investors must adapt. […]
WTO Crisis 2025: What This Means for Double Taxation Relief

The World Trade Organization (WTO), long viewed as the guardian of global trade, is now in deep crisis. In 2025, political deadlock, eroded trust, and a collapse in dispute resolution mechanisms have seriously weakened its influence. While attention has focused on trade barriers and supply chain issues, the impact on international tax systems is just […]
2025 EU Directive on WHT Reclaims: A Game-Changer?

Withholding tax (WHT) reclaims have long created difficulties for cross-border investors in the European Union. The current fragmented system causes delays, administrative complexity, and often leads to lost refunds—even when investors have a legal right to reclaim them. However, a major change is on the horizon. The European Commission has proposed a directive, due in […]
Top 5 Treaty Renegotiations in 2025 That Affect Foreign Investors

In 2025, the international tax landscape is shifting. Several treaty renegotiations now affect how foreign investors manage dividend tax and withholding tax (WHT). These changes are key for investors using tax treaties to avoid double taxation on dividend income from overseas shares. For investors, pension funds, and tax advisers, it is crucial to understand these […]
Why Custodians Are Under Pressure to Prove Tax Compliance

In today’s financial environment, custodians are under growing pressure to prove tax compliance—particularly regarding dividend tax and withholding tax (WHT). Regulators around the world are enforcing stricter rules and demanding transparency. As a result, custodians now carry greater responsibility for tax-related matters. Their role extends beyond safeguarding assets to ensuring compliance with complex global tax […]
Digitising Your Tax Documents: What You’ll Need for 2025 Claims

As global tax regulations grow more complex, investors and financial professionals are turning to digitisation to simplify tax compliance and maximise recovery. For 2025 claims, especially those involving dividend tax and withholding tax (WHT), having your tax documents in a digital and organised format is essential. This article explains why digitising your tax records matters, […]
How ASEAN’s Growing Tax Network Affects Dividend Reclaims

As the Association of Southeast Asian Nations (ASEAN) develops its regional tax framework, the implications for dividend reclaims and withholding tax (WHT) compliance are becoming more significant. For foreign investors eyeing the region’s vibrant capital markets—from Singapore and Malaysia to Thailand, Indonesia and Vietnam—understanding the nuances of ASEAN’s evolving tax landscape is vital for managing […]
Time Limits for WHT Reclaims in 2025: Country-by-Country Guide

Navigating the world of withholding tax (WHT) reclaims can feel overwhelming, especially when each country enforces strict deadlines for refunds. In 2025, investors, fund managers and tax professionals need to understand the unique time limits for recovering overpaid dividend tax across jurisdictions. Missing a filing deadline often means forfeiting potential refunds. This guide breaks down […]
CJEU Strikes Down Poland’s External-Management WHT Exemption Requirement

On 27 February 2025, the Court of Justice of the European Union (CJEU) delivered its judgment in Case C‑18/23, ruling that Poland’s Corporate Income Tax (CIT) exemption—limited to externally managed non-resident investment funds—violates Article 63(1) of the Treaty on the Functioning of the European Union (TFEU). This decision unlocks refund opportunities for internally managed funds […]