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...
The Benefits of Outsourcing the Withholding Tax Reclaim Function
The asset management industry was in a state of flux, even before Covid-19, with an increased emphasis on the reduction of costs and the maximisation of returns. Meeting and even exceeding the demands of clients has become the norm and clients expect their investment managers to be at the forefront of the latest technologies and solutions.
Withholding Tax on Separately Managed Accounts – An Overlooked Opportunity?
Introduction to SMAs Separately Managed Accounts (SMAs) are portfolios of individual assets managed by a professional money manager on behalf of an investor. Instead of investing in traditional mutual funds or Exchange Traded Funds (ETFs), where securities are pooled or track an index, SMAs allow investors to own the assets directly. SMAs have traditionally been reserved for high net worth individuals or institutional investors as the account minimums usually range between $100k-$250k or higher. Not only does this allow investors to take advantage of their personal tax situations but it adds...
France: Comparability Criteria for WHT Exemptions of Collective Investment Funds
A recent update published by the French tax authorities (FTA) on the 12th of August 2020 offers revised guidelines as to the requirements non-European Union (EU) collective investment funds must meet, in order to be entitled to withholding tax exemptions on French source dividends, pursuant to Article 119 bis, 2 of the French Tax Code.
US Withholding Tax Refunds from Canadian Pooled Fund Investments
By guest author Max Reed. Max is a cross-border tax lawyer and the founding partner of Polaris Tax Council Canada. WTax partners with Polaris Tax Council in recovering US withholding tax for investors of Canadian pooled funds.
UPDATE: Dividend Withholding Tax: What Happens Post the Brexit Transition Period?
Earlier this year, WTax outlined some of the withholding tax implications of Brexit (click here). This article explores the latest developments, on how the UK’s official withdrawal from the EU will affect the withholding taxes levied on UK-domiciled funds, once the transitional period ends at the end of 2020. This is in light of the European Commission’s announcement on the 7th of July 2020, in which it was confirmed and stakeholders were informed that as from the end of the transition period (31 December 2020), the EU rules in the field of asset management — in particular Directive...