Contractual Finnish UCITS Ruled Comparable to Corporate Luxembourg SICAV by CJEU
A judgement rendered by the Court of Justice in the European Union (CJEU) on 29 April 2021 in case C-480/19 – Veronsaajien oikeudenvalvontayksikkö (Revenus versés par des OPCVM) (“C-480/19”), could help non-Finnish corporate form investment funds (such as Luxembourg SICAVs) justify their eligibility for preferential Finnish withholding tax treatment going forward. Unlisted Luxembourg SICAVs have suffered unfavourable withholding taxes on Finnish sourced dividends for many years, but a new CJEU ruling could be the start of full withholding tax recovery for corporate-form investment funds.
Foreign Withholding Tax Reporting: Why Access, Transparency and Expertise are Key
Access to WHT Reclaim Reporting As an investor, the importance of optimizing foreign withholding tax (WHT) recoveries cannot be overstated. Reducing tax drag has an appreciable effect on investment performance, even more so if the reclaimed funds are reinvested over an extended period.
The Only Constant is Change: The Latest Trends in WHT and WHT Recovery
It’s often said that the only constant in life is change, and that the only certainties are death and taxes. Withholding tax on investment income is undoubtedly one of these certainties, but the industry is on the cusp of momentous shifts in the way taxes are levied, recovered and tracked.
What You Need to Know About Proposed Changes to Danish Dividend Withholding Tax Law
Recently proposed amendments to Denmark’s tax laws are expected to rectify the discriminatory withholding tax treatment of certain comparable Danish and foreign entities.
Everything You Need to Know About Double Tax Treaty Withholding Tax (WHT)
Understanding the Basics of Double Taxation on Investment Income Put simply, double taxation occurs when two countries tax the same income.
Is Hong Kong the World’s Next Fund Hub?
In February 2021, Hong Kong’s Financial Services and The Treasury Bureau (FSTB) issued a proposal for easier migration of foreign funds to Hong Kong, in order to encourage more locally domiciled funds and thereby boost the investment market in Hong Kong.
How to Capitalise on EU Law-Based Withholding Tax Reclaims
In the world of cross-border tax, it has been challenging for the European Commission to harmonise the different regulations and laws that govern EU-law based withholding tax reclaims. This adds complexity for institutional investment firms which need to navigate the withholding tax reclaim opportunities available to them through double taxation treaty agreements and previous tax discrimination case law commonly known as European Court of Justice claims.
Is a Complicated Tax Reclaim Process Leaving Pension Funds Out of Pocket?
Pension funds are usually tax-exempt in their home country but this is not always the case when they hold investments in foreign jurisdictions and, in most cases, the onus is on the pension fund to prove its tax-exempt status, when trying to reduce or eliminate foreign withholding taxes on investment income. Despite the availability of tax exemptions from foreign tax authorities, pensions funds don’t always maximize the refund opportunities available. The increased complexity and volume of documentation required by international tax authorities has resulted in an ever-growing backlog of...