The Impact of Queries on Your Withholding Tax Operations
Enhancing your withholding tax recovery with WTax’s query management solution When investors are entitled to lower withholding tax rates than the statutory rates withheld on dividend payments, the opportunity exists to reclaim excess taxes from foreign tax authorities. However, these reclaim applications are subject to potential queries and requests for further information to allow tax authorities to fully determine the eligibility for a refund of over-withheld taxes. Navigating the complexities of queried reclaim applications is crucial for ensuring the efficient processing of withholding...
The Luxembourg SICAV’s Guide to Additional Withholding Tax Recovery
WTax’s experience in managing withholding tax reclaims suggests that Luxembourg SICAV funds often overlook unexplored withholding tax reclamation opportunities, even when the funds have a recovery plan in place. Typically, these plans only address specific types of reclaims, leaving potential opportunities out of scope.
Five Essentials for Improving Withholding Tax Efficiency
In the intricate world of investment management, maximising returns is key, and that includes ensuring you’re not missing out on potential reclaims of foreign withholding tax.
Changes in Dutch Tax Laws: Withholding Tax Implications Investment Managers Should Know
In December 2023, the Netherlands approved significant tax changes aiming to streamline investment structures and combat dividend stripping. If you’re a Dutch investment manager or a foreign investment manager with interests in the Netherlands, your fund’s withholding tax recovery may be affected by these changes.
Treatment of 81-100 Group Trusts in France and Switzerland
In the second segment of the 81-100 Group Trust series titled: Barriers to Treaty Access for 81-100 Group Trusts, we explored the challenges that 81-100 Group Trusts encounter with regard to withholding tax relief in certain jurisdictions, providing a broad overview of how the relevant tax authorities perceive and treat 81-100 Group Trusts for tax purposes. In this third and final segment, we will be diving into the distinctive requirements and challenges experienced by 81-100 Group Trusts specifically in France and Switzerland.
BFH’s Verdict in L Fund Case Unleashes New Horizons for Foreign Investment Funds in Germany
The German Federal Fiscal Court (BFH) delivered its conclusive ruling in the L Fund case (I R 23/23), echoing the earlier European Court of Justice (ECJ) decision on 27 April 2023 (C-537/20). The BFH’s judgment, dated 11 October 2023 and published on 2 February 2024, signifies a notable development in tax jurisprudence as it aligns with the Court of Justice of the European Union’s (CJEU) interpretation of Article 63 of the Treaty on the Functioning of the European Union (TFEU).
Barriers to Treaty Access for 81-100 Group Trusts
In our opening segment on the 81-100 Group Trust series titled: Understanding 81-100 Group Trusts, we provided an overview of 81-100 Group Trusts and how they are structured, whilst also touching on the challenges related to withholding tax relief that they may encounter. In this second segment of the series, we will explore the intricacies of these challenges faced by 81-100 Group Trusts in certain jurisdictions by providing a broad overview of how tax authorities in different jurisdictions perceive 81-100 Group Trusts, highlighting their unique characteristics and nuances when it comes to...
WTax Continues to File German Reclaims Despite Industry Hold
Amidst the complexities of international taxation, WTax delivers a pivotal solution for institutional investors grappling with the recent changes in German tax filing procedures. In 2023, the German Tax Authority (BZSt) unveiled a new online portal (Elster) for withholding tax reclaim applications replacing the previous process of submitting hard copy paper-based applications. Despite its advancements, the portal currently does not support bulk submissions which has forced many providers to place German reclaim filings on hold for the time being, prompting the need for a robust, agile...