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...
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.