Unlocking WHT Reclaims Under the New China–Italy DTA: 2026 Changes?
The new China–Italy double tax agreement (DTA) entered into force on 19 February 2025. From 1 January 2026, it applies to withholding taxes (WHT). This agreement reshapes dividend tax and reclaim strategies by resetting rates, eligibility tests and processes. For investors between the two countries, the changes are material and require proactive planning. Dividend: From […]
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 […]
Detecting Treaty Shopping Risks Before They Trigger Anti-Abuse Rules
Treaty shopping is no longer a distant concern. It has become a frontline risk that can undermine dividend tax positions and block withholding tax (WHT) reclaims. The OECD’s Multilateral Instrument (MLI), the Principal Purpose Test (PPT), limitation-on-benefits (LoB) clauses, and national anti-abuse rules have reshaped the landscape. If you wait until an audit or a […]
Avoiding Duplicate Reclaims: When Multiple Parties File for the Same Income
Duplicate WHT reclaims are a silent value-eroder. They invite audits, stall refunds, and can turn a valid dividend tax claim into a costly rejection. For asset managers, custodians, trusts, and high-net-worth investors, the operational risk is clear: when two parties file for relief on the same income, someone loses—and it might be you. This article […]
How the EU’s FASTER Initiative Could Revolutionise Withholding Tax Relief
Introduction: A Bold Step Towards Simplified Withholding Tax Relief in the EU Cross-border dividend tax inefficiencies have long challenged the European Union. The FASTER initiative, short for “Faster and Safer Tax Excess Relief”, aims to resolve these issues. It introduces streamlined processes for withholding tax (WHT) relief across member states. By simplifying relief at source […]
U.S. Withholding Tax for Foreign Investors: What’s New in 2025
Foreign investors continue to view the United States as a profitable destination for portfolio investment, particularly for dividend-generating assets. However, 2025 has brought several changes to the U.S. withholding tax (WHT) system. For institutional investors, pension funds, and asset managers based outside the U.S., staying updated is vital. These changes affect compliance and the ability […]
Tax Leakage in Dual-Listed Shares: Understanding Withholding Risks
Dual-listed shares offer global investors better access to markets and increased trading flexibility. But they also carry hidden tax risks. One of the biggest is withholding tax leakage, which happens when the same dividend is taxed at different rates depending on the listing location. Many investors do not realise how much dividend tax they lose […]