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 […]
Why Your Tax Reclaim Was Denied: Common Errors

Withholding tax (WHT) on dividends is a persistent challenge for international investors. Institutional investors and pension funds often seek to reclaim excess WHT charged by foreign tax authorities. However, many claims are unsuccessful. Denials usually arise from avoidable errors. Understanding common mistakes can help investors improve their reclaim success and navigate dividend tax regulations across […]
Withholding Tax in Frontier Markets: Risks and Recovery Options

As investors seek higher returns in fast-growing regions, frontier markets have become more attractive. These economies—less advanced than emerging markets but more accessible than the least developed nations—offer strong dividend yields and capital growth potential. However, they also pose significant risks, particularly in the form of complex tax regimes. One of the most pressing issues […]
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. […]
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 […]
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 […]
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 […]