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· Italian WHT: New Exemption for Qualifying EU/EEA Funds · Who Is WTax & What Do We Do? · Withholding Tax on Separately Managed Accounts – An Overlooked Opportunity? · France: Comparability Criteria for WHT Exemptions of Collective Investment Funds · US Withholding Tax Refunds from Canadian Pooled Fund Investments · UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period? · Know More About International Withholding Tax Recovery · Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance · To Accrue or Not to Accrue — That is the Question · The Race to Withholding Tax Recovery – Statutes of Limitations · Tax Exemption for CITs · Cayman LLCs – Unlocking Withholding Tax Recoveries through a Unique Investment Vehicle · Companies Turn to Withholding Tax Recovery Opportunities as Dividend Payouts Plummet · Withholding Tax: The Quintessential Guide to European Court of Justice (ECJ) Claims · Swedish Withholding Tax Case Win For US Investment Fund Spells Good News for Other Foreign Investors · Withholding Tax: What Happens Post the Brexit Transition Period? · Pension Funds, Are You Claiming the Withholding Tax that is Rightfully Yours? · The 19th FONDS Professionell Kongress 2020 · Finland Taxation Changes Spell Big Opportunities for Foreign Investors in 2020 · DTT Withholding Tax Reclaim. Made Easy. · The W-8BEN-E Form: Using it for Withholding Tax Benefits · Ireland: Withholding Tax Rates Hiked up by 5% in 2020 · Foreign Investments: The Challenges of Withholding Tax · Withholding tax & the free movement of capital in the EU: what investors needs to know · Withholding tax claims for international investors in Europe: The case of Emerging Markets Series of DFA Investment Trust Company v Dyrektor Izby Skarbowej w Bydgoszczy · Fokus Bank ASA v The Norwegian State: A test case for the single market
· Italian WHT: New Exemption for Qualifying EU/EEA Funds · Who Is WTax & What Do We Do? · Withholding Tax on Separately Managed Accounts – An Overlooked Opportunity? · France: Comparability Criteria for WHT Exemptions of Collective Investment Funds · US Withholding Tax Refunds from Canadian Pooled Fund Investments · UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period? · Know More About International Withholding Tax Recovery · Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance · To Accrue or Not to Accrue — That is the Question · The Race to Withholding Tax Recovery – Statutes of Limitations · Tax Exemption for CITs · Cayman LLCs – Unlocking Withholding Tax Recoveries through a Unique Investment Vehicle · Companies Turn to Withholding Tax Recovery Opportunities as Dividend Payouts Plummet · Withholding Tax: The Quintessential Guide to European Court of Justice (ECJ) Claims · Swedish Withholding Tax Case Win For US Investment Fund Spells Good News for Other Foreign Investors · Withholding Tax: What Happens Post the Brexit Transition Period? · Pension Funds, Are You Claiming the Withholding Tax that is Rightfully Yours? · The 19th FONDS Professionell Kongress 2020 · Finland Taxation Changes Spell Big Opportunities for Foreign Investors in 2020 · DTT Withholding Tax Reclaim. Made Easy. · The W-8BEN-E Form: Using it for Withholding Tax Benefits · Ireland: Withholding Tax Rates Hiked up by 5% in 2020 · Foreign Investments: The Challenges of Withholding Tax · Withholding tax & the free movement of capital in the EU: what investors needs to know · Withholding tax claims for international investors in Europe: The case of Emerging Markets Series of DFA Investment Trust Company v Dyrektor Izby Skarbowej w Bydgoszczy · Fokus Bank ASA v The Norwegian State: A test case for the single market

France: Comparability Criteria for WHT Exemptions of Collective Investment Funds

A recent update published by the French tax authorities offers revised guidelines as to which requirements non-EU collective investment funds must meet in order to be entitled to withholding tax exemptions on French source dividends.

A recent update published by the French tax authorities offers revised guidelines as to which requirements non-EU collective investment funds must meet in order to be entitled to withholding tax exemptions on French source dividends.

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US Withholding Tax Refunds from Canadian Pooled Fund Investments

Canadian tax-exempt entities that invest through Canadian pooled funds may apply for a refund of three years of US withholding taxes paid through the fund.

Canadian tax-exempt entities that invest through Canadian pooled funds may apply for a refund of three years of US withholding taxes paid through the fund.

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UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period?

WTax unpacks the post-Brexit impacts of withholding tax on UK-domiciled UCITS funds.

Earlier this year, WTax outlined some of the withholding tax implications of Brexit. This article explores the latest developments, on how the UK’s official withdrawal from the EU will affect the withholding taxes levied on UK-domiciled funds, once the transitional period ends at the end of 2020.

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Know More About International Withholding Tax Recovery

There is a great deal to be gained from understanding the inner workings of international withholding tax (WHT) recovery – especially when it comes to dividend income. Institutional investment firms stand to increase their clients’ ROI on foreign investments by up to 0.5% by simply unlocking the various dividend WHT reclaim methodologies. If you want to know more about international withholding tax recovery, this article will provide a good foundation.

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Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance

While global markets continue to recover from the COVID-19 pandemic and uncertainty still lingers around the immediate future of dividends, investment firms should be looking for sound and innovative ways to boost investment performance.

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To Accrue or Not to Accrue — That is the Question

In the accounting world, the eternal goal is to ensure that financial records accurately reflect the financial position of a particular entity at a point in time. This generally means accounting for transactions when they occur as opposed to when the cash implications are felt.

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The Race to Withholding Tax Recovery – Statutes of Limitations

Many institutional investment firms are unaware of the benefits of withholding tax services in South Africa and the potential for tax refunds by using these services. South African funds stand to gain welcome cash injections to their bottom lines by making use of double tax treaty agreements and European Court of Justice case law. Particularly in Europe, withholding tax refunds are claimable if certain criteria are met.

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Tax Exemption for CITs

Collective Investment Trusts (CITs) or group trusts as they are commonly referred to, are addressed in Internal Revenue Service (IRS) Revenue Ruling 81-100 (as modified by Revenue Ruling 2004-67, Revenue Ruling 2011-1 and Revenue Ruling 2014-24). The IRS provided special dispensation for CITs in the form of exemption from income tax to ensure that these structures can be used to pool assets of various qualified retirement plans, individual retirement accounts and other similar plans without creating unnecessary income tax obligations. The goal is to ensure that pension-related money and the returns earned through investing that money, are not eroded through income taxes.

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Cayman LLCs – Unlocking Withholding Tax Recoveries through a Unique Investment Vehicle

For many years, the US investment vehicle landscape has had a strong affinity to Cayman domiciled structures. Immense benefits can be achieved for US tax-exempt investors as well as non-US investors in US structures through the use of offshore, Cayman Islands domiciled feeder funds. However, in setting up these structures, withholding tax (and the ability to reclaim taxes incurred on foreign investment income) is often overlooked.

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Companies Turn to Withholding Tax Recovery Opportunities as Dividend Payouts Plummet

While global dividend payouts are set to decrease by 15% this year, retrospective withholding tax recovery could be the silver lining.

2020 has certainly been a challenging year and very few corporates around the world will be unaffected by the COVID-19 pandemic. It’s no surprise that dividend payouts have decreased drastically and in this uncertain time, it’s difficult to predict how long this downturn will last. Media sources such as Forbes and CNBC commented on the […]

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Withholding Tax: The Quintessential Guide to European Court of Justice (ECJ) Claims

Most institutional investment firms are well aware of their reclaim opportunities within double taxation treaty claims and exemptions. However, ECJ claims are often overlooked and go unrecovered.

This is because the claims are highly complex and require a deep knowledge of the legislation, past court cases and legal precedent set to be able to achieve refunds. Moreover, in most cases, custodians (who are often an investor’s go-to point for DTT claims) are generally unable to help with ECJ claims. What is the […]

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Swedish Withholding Tax Case Win For US Investment Fund Spells Good News for Other Foreign Investors

International foreign investors will welcome the news of a US investment fund’s win over the Swedish tax authorities for owed withholding tax refunds of $2.6 million.

Last month, the Swedish Supreme Administrative Court issued a milestone judgement stating that Swedish tax authorities should not deny withholding tax refunds (that were requested based on EU Law) to a US investment fund, based on the Fund’s legal structure.   This is good news for the international investment community seeking withholding tax refunds from Sweden […]

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Withholding Tax: What Happens Post the Brexit Transition Period?

The 31st of January has come and gone and the UK has officially left the European Union. As the sign read outside the European parliament; “It’s not goodbye, it’s au revoir”. But let’s talk about goodbye.

The 31st of January has come and gone and the UK has officially left the European Union. As the sign read outside the European parliament; “It’s not goodbye, it’s au revoir”. But let’s talk about goodbye.  There is still a lot of uncertainty around the implications that Brexit will have on international withholding taxes. For […]

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Pension Funds, Are You Claiming the Withholding Tax that is Rightfully Yours?

Although pension funds are entitled to reclaim 100% of their foreign withholding taxes, many are not actually getting the full refunds owed to them.

Although pension funds are entitled to reclaim a large majority of their foreign withholding taxes, many are not actually getting the full refunds owed to them.

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The 19th FONDS Professionell Kongress 2020

Event: FONDS Professionell Kongress 2020
Date: 29 - 31 January 2020
Place: Congress Center Rosengarten, Mannheim

We’ll be attending the FONDS professionell Conference 2020!  Book a slot with us, let’s grab a coffee and discuss the complex world of foreign withholding tax reclaim. We’ll be helping businesses explore every reclaim opportunity from Double taxation agreement claims to European Court of Justice claims.  You owe it to your investments to increase your […]

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Finland Taxation Changes Spell Big Opportunities for Foreign Investors in 2020

Finnish Tax Authorities make Finnish investment funds more attractive to foreigners by relaxing taxation legislation

Foreign investors should take advantage of the 2019-passed amendments to Finnish legislation related to the taxation of investment funds. These amendments came into force on January 1st 2020 and are aimed at making Finland a more attractive investment market as well as allowing Finnish investment management firms to explore international investment opportunities without added taxation […]

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DTT Withholding Tax Reclaim. Made Easy.

The Essential 2020 Guide to Double Taxation Agreements: Withholding Tax Refunds

Introduction This guide to Double taxation Agreements and the withholding tax benefits, is intended to provide essential information of Double Taxation Agreements within the context of dividend withholding tax recovery. Why Foreign Investors Need to Understand International Double Taxation Treaties It has become a necessity for any foreign investor to understand the intricacies of international […]

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The W-8BEN-E Form: Using it for Withholding Tax Benefits

How to complete a W-8BEN-E form for withholding Tax benefits

For many global investment management companies, the completion of the W-8BEN-E form is complicated. Ultimately, the lack of understanding over its completion infringes on many investment firms’ ability to receive US dividend or interest payments at the treaty rate. This is especially true for those investment firms in developing countries. This guide explains the purpose […]

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Ireland: Withholding Tax Rates Hiked up by 5% in 2020

Ireland seeks to boost its revenue by increasing withholding tax by 5%.

Investors in Ireland must prepare for increased withholding tax rates in 2020 as Ireland increases the withholding tax rate in an effort to create a revenue boost to their exchequer. The dividend withholding tax percentage increased from the previous 20% to 25% and has been effective since 1 January 2020. The Irish Times reported that […]

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Foreign Investments: The Challenges of Withholding Tax

This article explores the complexities of withholding tax reclaim for foreign investors and how you can maximise on tax refund opportunities.

2020 looks set to be the year where investors secure profitable growth by venturing into new demographic segments and geographies, leaving their comfort zones to perform new activities and harnessing investment technology to unlock agility and value (source). But despite technological uptake and a more explorative approach to investing, most investors are still completely in […]

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Withholding tax & the free movement of capital in the EU: what investors needs to know

As a political and economic union of sovereign states, understanding the regulatory framework of the European Union presents a unique challenge for investors. The mechanics of claiming withholding tax in the EU are a case in point. Any investor seeking to reclaim dividend withholding tax needs to take into account the relevant national legislation, as […]

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Withholding tax claims for international investors in Europe: The case of Emerging Markets Series of DFA Investment Trust Company v Dyrektor Izby Skarbowej w Bydgoszczy

The free movement of capital is woven into the framework of the European Union. Article 63 of the Treaty on the Functioning of the European Union (TFEU) states that “all restrictions on the movement of capital between Member States and between Member States and third countries shall be prohibited”. What are the limits on the […]

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Fokus Bank ASA v The Norwegian State: A test case for the single market

The European Single Market was founded on the principle of guaranteeing the “four freedoms” of open economies: free movement of capital, services, goods and labour between member states. The commitment to a common market with parity between states has clear implications for member-state tax fiscal policy, and for tax policy in particular. Free movement of […]

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Related Articles

· Italian WHT: New Exemption for Qualifying EU/EEA Funds · Who Is WTax & What Do We Do? · Withholding Tax on Separately Managed Accounts – An Overlooked Opportunity? · France: Comparability Criteria for WHT Exemptions of Collective Investment Funds · US Withholding Tax Refunds from Canadian Pooled Fund Investments · UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period? · Know More About International Withholding Tax Recovery · Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance · To Accrue or Not to Accrue — That is the Question · The Race to Withholding Tax Recovery – Statutes of Limitations · Tax Exemption for CITs · Cayman LLCs – Unlocking Withholding Tax Recoveries through a Unique Investment Vehicle · Companies Turn to Withholding Tax Recovery Opportunities as Dividend Payouts Plummet · Withholding Tax: The Quintessential Guide to European Court of Justice (ECJ) Claims · Swedish Withholding Tax Case Win For US Investment Fund Spells Good News for Other Foreign Investors · Withholding Tax: What Happens Post the Brexit Transition Period? · Pension Funds, Are You Claiming the Withholding Tax that is Rightfully Yours? · The 19th FONDS Professionell Kongress 2020 · Finland Taxation Changes Spell Big Opportunities for Foreign Investors in 2020 · DTT Withholding Tax Reclaim. Made Easy. · The W-8BEN-E Form: Using it for Withholding Tax Benefits · Ireland: Withholding Tax Rates Hiked up by 5% in 2020 · Foreign Investments: The Challenges of Withholding Tax · Withholding tax & the free movement of capital in the EU: what investors needs to know · Withholding tax claims for international investors in Europe: The case of Emerging Markets Series of DFA Investment Trust Company v Dyrektor Izby Skarbowej w Bydgoszczy · Fokus Bank ASA v The Norwegian State: A test case for the single market
· Italian WHT: New Exemption for Qualifying EU/EEA Funds · Who Is WTax & What Do We Do? · Withholding Tax on Separately Managed Accounts – An Overlooked Opportunity? · France: Comparability Criteria for WHT Exemptions of Collective Investment Funds · US Withholding Tax Refunds from Canadian Pooled Fund Investments · UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period? · Know More About International Withholding Tax Recovery · Withholding Tax Refunds: Unlocking 0.5% Increase in Fund Performance · To Accrue or Not to Accrue — That is the Question · The Race to Withholding Tax Recovery – Statutes of Limitations · Tax Exemption for CITs · Cayman LLCs – Unlocking Withholding Tax Recoveries through a Unique Investment Vehicle · Companies Turn to Withholding Tax Recovery Opportunities as Dividend Payouts Plummet · Withholding Tax: The Quintessential Guide to European Court of Justice (ECJ) Claims · Swedish Withholding Tax Case Win For US Investment Fund Spells Good News for Other Foreign Investors · Withholding Tax: What Happens Post the Brexit Transition Period? · Pension Funds, Are You Claiming the Withholding Tax that is Rightfully Yours? · The 19th FONDS Professionell Kongress 2020 · Finland Taxation Changes Spell Big Opportunities for Foreign Investors in 2020 · DTT Withholding Tax Reclaim. Made Easy. · The W-8BEN-E Form: Using it for Withholding Tax Benefits · Ireland: Withholding Tax Rates Hiked up by 5% in 2020 · Foreign Investments: The Challenges of Withholding Tax · Withholding tax & the free movement of capital in the EU: what investors needs to know · Withholding tax claims for international investors in Europe: The case of Emerging Markets Series of DFA Investment Trust Company v Dyrektor Izby Skarbowej w Bydgoszczy · Fokus Bank ASA v The Norwegian State: A test case for the single market