When One Company Drives the Numbers: Dividend Concentration and Reclaim Exposure
In certain markets, a large share of total dividends may come from a small number of high-dividend-paying companies. This kind of concentration shapes the overall dividend landscape, influencing payout cycles and the flow of cross-border income.
New Competent Authority Agreement Unlocks Danish Tax Relief for U.S. 81-100 Group Trusts
In a significant development for U.S 81-100 Group Trusts, the United States and Denmark signed a new Competent Authority Arrangement (CAA) on 25 March 2025, fundamentally reshaping the tax treatment of these structures under the U.S.–Denmark tax treaty.
U.S. Proposes Tax Hikes on Countries with “Unfair Foreign Taxes”
In May 2025 the U.S. House of Representatives passed a broad tax and spending bill known as the “One Big Beautiful Bill Act” (H.R.1). Among its many provisions is Section 899, a proposed measure that would allow the U.S. Treasury to impose increased withholding tax rates on residents of countries that implement what the U.S. defines as “unfair foreign taxes.”
CJEU Strikes Down Polish Investment Fund Tax Rule: Major Win for Internally Managed Investment Funds
February 2025 marked a turning point for cross border investment funds in the European Union (EU). The Court of Justice of the European Union (CJEU) has ruled that a key condition under Polish tax law—requiring non-resident investment funds to appoint an external management company in order to qualify for a withholding tax exemption—violates EU law.
Spanish Supreme Court Refers Neutralization Debate to the ECJ
In recent years, an important debate has unfolded in Spanish courts regarding withholding tax imposed on dividends paid by Spanish companies to US Regulated Investment Companies (RICs).