Understanding 81-100 Group Trusts
As part of WTax’s commitment to continually boost withholding tax recovery opportunities for institutional investors, WTax will be releasing a series of articles to explore some common withholding tax relief-associated challenges faced by 81-100 Group Trusts. Given the distinctive and complex nature of Revenue Ruling 81-100 Group Trusts, this article series aims to explain the implications of their structure on withholding tax recoveries and will provide suggestions regarding how to manage these unique challenges. It will also present updates on prevalent markets where these structures are...
Preparing Your 2024 Foreign Withholding Tax Recovery Process in 3 Guided Steps
The start of a new year marks an opportune time to critically assess your withholding tax recovery strategy and processing schedule, a step that could be key to bolstering investment performance throughout 2024.
Essential Steps to Optimise Your Withholding Tax Process
Benchmarking and accurately measuring the effectiveness of a withholding tax relief and reclaim process can prove difficult when the only reference point is experience. Therefore, a holistic perspective is required to identify areas of inefficiency and opportunities for process optimisation. Optimising this process can also be challenging, as it requires proficiency with various administrative tasks, clear communication, and diligent monitoring to maintain peak efficiency and mitigate potential risks at every step.
Partnering with WTax: A 2024 Roadmap for Diversifying and Enhancing Your Back Office Solutions
In the dynamic world of asset servicing, diversifying and enhancing back office solutions is essential for maintaining a competitive edge and meeting evolving client needs. The WTax Partnership Ecosystem stands at the forefront of this evolution, offering a unique opportunity to access an extensive indirect tax recovery infrastructure. WTax provides customised partnership programmes with fund administrators, fund service providers, management companies and others, ensuring shared growth and maximum collaborative benefits.
EU and National Law Withholding Tax Reclaims: No Time Like the Present
Over the past few years there have been numerous developments in the withholding tax space, owing to several notable cases which have been brought before the Court of Justice of the European Union (CJEU), as well as the relevant EU Member States’ National Courts. The applicants in these cases range from investment funds to pension funds and the subject thereof covers mostly one important principle: the free movement of capital.
The European Commission’s FASTER Directive: Transforming Withholding Tax Procedures in the EU
On 19 June 2023, the European Commission published a legislative proposal for a Council Directive (hereinafter “the Directive”) that aims to make withholding tax procedures in the European Union (EU) more efficient and secure for investors, financial intermediaries and Member States.
A Consequence of War: A look into the effects of the Russia-Ukraine Conflict on Double Taxation Treaties and Withholding Tax Recovery
When thinking of the factors that may affect one’s ability to recover excess withholding tax, war is not usually one that springs to mind. However, in a world as complexly intertwined as ours, socio-political events have widespread ramifications. The recent, major escalation of the Russo – Ukrainian War stands testament to this. Alongside the extensive humanitarian consequences the military predicament has wreaked on the region and the world, diminished withholding tax recovery may be another unfortunate side-effect of the changing political landscape.
Spanish Supreme Court Confirms Discrimination Against Foreign Hedge Funds
The Spanish Supreme Court, being the highest court of appeals, laid down two separate judgements regarding the withholding tax rate which is currently levied on foreign hedge funds, also referred to as alternative investment funds (“AIFs”) or non-harmonised funds, which are resident in the European Union. The Court confirmed that the disparity between the withholding tax rate levied on non-Spanish hedge funds and that levied on comparable Spanish hedge funds is contrary to the Free Movement of Capital in Article 63 of the Treaty on the Functioning of the European Union (TFEU).