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).
Seeing the Full Picture in Withholding Tax Recovery: Why Better Timelines Matter
In the world of withholding tax recovery, timing is everything.
New Vivendi Spin-Off Triggers Withholding Tax Reclaim Opportunity
Nature of the Transaction Vivendi recently completed a spin-off, distributing shares in three newly separated entities—Canal+, Havas N.V., and Louis Hachette Group—to its existing shareholders, on a one-for-one basis for each Vivendi share held.
Maximizing Withholding Tax Recovery for Sovereign Wealth Funds: Three Key Questions to Optimize Returns
Sovereign wealth funds (SWFs) are entrusted with managing national assets to ensure long-term financial stability. However, many SWFs miss out on significant withholding tax recovery opportunities, reducing their net investment returns.