Our Expert Blogs
The European Union’s Faster and Safer Relief of Excess Withholding Taxes directive has crossed the finish line and now moves into execution. The Council adopted the measure on 10 December 2024, with publication in the Official Journal on 10 January 2025. This is no longer theory. It is policy, and it will reshape how dividend […]
The new China-Italy Double Tax Agreement resets expectations. Many investors ask whether dividend withholding tax (WHT) drops in 2025. It does not. The treaty is live, but the reduced rates bite for income derived on or after 1 January 2026. Treat 2025 as build time. Align policy, paperwork, and process now. That is how you […]
Switzerland’s move to online refunding of withholding tax (WHT) on dividends has been framed as a speed play. The reality is more nuanced. The Swiss Federal Tax Administration (SFTA) has expanded its ePortal so claimants can initiate a refund request online, track status, and manage permissions. The statutory framework is unchanged: Switzerland levies a 35 […]
Investors keep underestimating how hard Germany’s anti-treaty-shopping rule bites. Section 50d(3) of the German Income Tax Act (Einkommensteuergesetz, EStG) decides whether your dividend withholding tax (WHT) relief holds up. The rule was recast in 2021. In March 2025 the Federal Central Tax Office (Bundeszentralamt für Steuern, BZSt) refined its guidance again. If you rely on […]
Dutch dividend withholding tax (WHT) has always been a rate conversation on the surface and a substance conversation underneath. The rate looks simple. The policy and case law now make it anything but. If you want structures that stand up to audits, you need to engineer them for anti-abuse, hybrid neutrality, and conditional source rules, […]
Withholding tax (WHT) on dividends is simple in policy and messy in practice. Cash sits with tax authorities while investors chase documents, signatures and timelines that do not align. Governance is the difference between a sluggish reclaim and a predictable dividend tax recovery pipeline. This article sets out an execution model built on playbooks, service-level […]
Beneficial ownership decides who gets treaty relief on dividend tax and who does not. Auditors, revenue authorities and courts keep asking the same question: who actually enjoys the income, bears the risk and controls the cash flows? If your evidence cannot answer that, your reclaim of Withholding Tax (WHT) will drag or collapse. This article […]
Dividend withholding tax (WHT) is one of the most visible friction costs on cross-border profit flows in the European Union. It hits cash at the moment of payment and often stays trapped for years. The European Union (EU) Parent-Subsidiary Directive sits at the centre of that picture. It was designed to remove economic double taxation […]
Sweden dividend WHT: simple rule, messy reality Sweden’s approach to dividend withholding tax (WHT) looks clear on paper. The headline rate is 30 percent under the coupon tax law. Relief at source or a refund is available under treaties or domestic law. However, non-resident collective investment vehicles (CIVs) still lose cash because process and proof […]
Denmark rewired its approach after the dividend-refund scandal. If you want cash back on dividend withholding tax (DWT), you now need to show real ownership, real trades and real cash flows. Anything vague slows the claim. Anything inconsistent kills it. That is the operational reality. The new baseline for DWT claims The Danish Tax Agency […]