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Insights

Stay updated on global withholding tax changes, rates, treaties, reclaims, and litigation

Topics

APRIL 22, 2025 • 4 minute read

Italian supreme court affirms ‘look-through’ approach in withholding tax exemption

Italy’s Supreme Court affirms the look-through approach for WHT exemptions, clarifying that beneficial ownership—not form—drives eligibility for EU-based investors.

Tax news

APRIL 16, 2025 • 2 minute read

Taiwan MOF Extends Application Period for Tax Treaty Benefits Under Amended Article 34 of Double Taxation Regulations

Taiwan's MOF extends the application period for tax treaty benefits from 5 to 10 years, enhancing consistency and fairness for nonresident taxpayers.

Tax news

MARCH 25, 2025 • 4 minute read

Polish Tax Exemption for Investment Funds Ruled in Breach of EU Law: Implications for Investors

Poland's tax policy for investment funds has been deemed non-compliant with EU law, affecting cross-border investment strategies. Discover the implications for investors across Europe.

Tax news

MARCH 18, 2025 • 3 minute read

Swedish Supreme Administrative Court’s Ruling in the KEVA Case: A Precedent for Wider Pension Fund Claims?

The Swedish court's ruling in the KEVA case could expand pension fund claims, challenging Sweden's withholding tax policies.

Tax news

FEBRUARY 18, 2025 • 2 minute read

Germany: WHT Refunds for foreign investment funds underway

Learn about Germany's landmark court ruling on withholding tax refunds for foreign investment funds and the compliance challenges they face in reclaiming €7.5 billion.

JANUARY 23, 2025 • 5 minute read

CJEU: Spanish Loss-Making Rules Found in Violation of Article 63 TFEU

CJEU rules Biscay's tax laws breach Article 63 TFEU, impacting cross-border investments and favoring resident companies.

Tax news

JANUARY 8, 2025 • 2 minute read

The most important tax court decisions regarding EU withholding tax reclaims of 2024

Explore key 2024 EU tax court decisions on withholding tax reclaims, including major directives and landmark rulings impacting foreign investment funds.

Tax news

DECEMBER 17, 2024 • 2 minute read

The Adoption of the FASTER Directive: A New Era for Withholding Tax Relief in the EU

Discover how the FASTER Directive is set to transform withholding tax relief in the EU, enhancing transparency and efficiency while combating tax fraud across Member States.

Tax news

NOVEMBER 12, 2024 • 7 minute read

XX case: ECJ issues another landmark ruling on free movement of capital WHT reclaim

The ECJ's landmark ruling challenges Dutch tax law, affirming that it discriminates against non-resident companies in dividend taxation, impacting EU capital movement principles.

Tax news

OCTOBER 4, 2024 • 5 minute read

Dutch Supreme Court Tightens Rules on Tax Relief for Foreign Investment Funds: What You Need to Know

Explore the Dutch Supreme Court's latest ruling on tax relief for foreign investment funds and its potential impact on cross-border taxation within the EU.

Tax news

SEPTEMBER 13, 2024 • 6 minute read

German Federal Fiscal Court Rules in Favor of Foreign Investment Funds: A Landmark Decision on Tax Refunds

The German Federal Fiscal Court's ruling grants foreign funds tax refunds on dividends, reinforcing EU principles on non-discrimination and the free movement of capital.

Tax news

AUGUST 26, 2024 • 6 minute read

Navigating Cross-Border Taxation: Insights from the L Fund Case

Explore the complexities of cross-border taxation and discover key insights from the landmark L Fund case.

Tax news

AUGUST 1, 2024 • 4 minute read

CJEU Judgment in KEVA Case

CJEU rules Swedish tax law violates Article 63 TFEU by unfairly taxing non-resident pension funds, restricting free movement of capital.

Tax news

JULY 29, 2024 • 2 minute read

EU Challenges Dutch Tax Law: A Step Towards Equitable Investment Practices

The EU targets Dutch tax practices to promote fair investment across member states, highlighting the importance of equitable financial policies.

Tax news

JUNE 27, 2024 • 3 minute read

3 steps to address EU National Courts' Non-Compliance with ECJ Rulings on Free Movement of Capital and Withholding Tax

Discover effective strategies to address EU national courts' non-compliance with CJEU rulings on free movement of capital and withholding tax.

Knowledge hub

MAY 16, 2024 • 4 minute read

EU Council agrees on new rules for FASTER proposal

EU Council endorses new rules to expedite double taxation relief, boost cross-border investments, and fight tax fraud.

Tax news

APRIL 25, 2024 • 3 minute read

Challenges in Germany's Dividend Withholding Tax Procedures

Explore Germany's complex dividend withholding tax procedures, revealing processing delays and increased rejection rates that challenge foreign investors and demand urgent reform.

MARCH 25, 2024 • 5 minute read

CJEU Attorney General's Opinion in KEVA Case: Assessing Tax Discrimination and Free Movement of Capital within EU Law

Explore the implications of the CJEU Attorney General's opinion on tax discrimination and capital movement in the EU.

Tax news

MARCH 7, 2024 • 8 minute read

The impact of diverging concepts of beneficial ownership on withholding tax reclaims

Explore the complexities of inconsistent beneficial ownership interpretations and their impact on reclaiming over-withheld taxes in the EU. Discover challenges and strategies for navigating this landscape.

Knowledge hub

FEBRUARY 29, 2024 • 6 minute read

Executive summary of Polish court ECJ claim

Polish court sides with Canadian fund on tax refund, highlighting EU law's impact on international tax equity.

Tax news

FEBRUARY 12, 2024 • 6 minute read

Navigating Dutch Tax Transformations: Impact on Mutual Funds, Exempt Investment Institutions, and Foreign Investment Entities

Explore the upcoming Dutch tax changes impacting mutual funds and foreign investment entities, effective January 2025, and how these shifts may affect your investment strategies.

Tax news

FEBRUARY 2, 2024 • 6 minute read

The effects of the OECD's Pillar Two on Institutional Investors

Explore how OECD's Pillar Two reshapes international taxation, impacting institutional investors beyond multinational enterprises.

Tax news

JANUARY 30, 2024 • 3 minute read

Dividend Tax Withholding Per Country: The Differences in Rates and Rules​

Explore how varying dividend tax rates impact your investments and learn strategies to optimize tax relief across different countries.

Knowledge hub

DECEMBER 15, 2023 • 5 minute read

What is happening to foreign pension funds' dividend withholding tax reclaims in the Netherlands?

Dutch tax authorities reinterpret rules, affecting foreign pension funds' dividend withholding tax reclaims. Disputes arise over statute of limitations and objective comparability.

Tax news

SEPTEMBER 20, 2023 • 3 minute read

New Dutch dividend stripping measures introduced

On September 19, the Dutch government presented its 2024 Budget Plan, introducing new measures against dividend stripping.

Tax news

JUNE 21, 2023 • 7 minute read

European Commission issues proposal for EU withholding tax system

Explore the European Commission's recent proposal for a unified EU withholding tax system, featuring a digital tax residence certificate and streamlined relief procedures.

Tax news

JUNE 1, 2023 • 1 minute read

Dividend Withholding Tax in Austria

Explore Austria's dividend withholding tax rates, double tax treaties, and methods to secure reduced taxation for foreign investors.

Knowledge hub

DECEMBER 16, 2022 • 4 minute read

German Supreme Court dismisses appeal in Canadian pension fund ECJ reclaim

The German Supreme Court's decision ends an 11-year legal battle, denying the Canadian pension fund's ECJ reclaim and maintaining the withholding tax.

Tax news

DECEMBER 14, 2022 • 2 minute read

Dutch Court of Appeals refers ECJ reclaim case to European Court of Justice

On December 14th, a Dutch court of appeals issued a decision in which it referred the case to the European Court of Justice (ECJ) for a preliminary ruling.

Tax news

SEPTEMBER 29, 2022 • 1 minute read

Denmark proposes dividend withholding tax for foreign government investors

Denmark's new tax proposal may challenge EU free movement rules, applying a 22% dividend tax on foreign government investors.

Tax news

SEPTEMBER 21, 2022 • 4 minute read

Dutch tax authorities claw back millions in ECJ reclaims

Dutch tax authorities initiate a large-scale review to reclaim millions in ECJ refunds from foreign pension funds, questioning their comparability to domestic counterparts.

Tax news

SEPTEMBER 14, 2022 • 3 minute read

Italian Supreme Court says US pension fund is entitled to same reduced dividend withholding tax rate as Italian pension funds

US pension funds can now enjoy the same reduced dividend withholding tax rates as Italian counterparts, thanks to a landmark ruling by the Italian Supreme Court.

Tax news

SEPTEMBER 9, 2022 • 3 minute read

Taiwan lifts FINI withholding tax statement requirement

Taiwan simplifies tax processes for Foreign Institutional Investors, aligning with eco-friendly trends and enhancing market development.

Tax news

AUGUST 31, 2022 • 3 minute read

Cum-ex transactions explained

Uncover the mechanics and implications of cum-ex transactions, a complex tax fraud scheme impacting European economies.

Knowledge hub

AUGUST 2, 2022 • 2 minute read

EU wide withholding tax system: European Commission public consultation summary report

Explore the European Commission's summary report on the proposed EU-wide withholding tax system and its potential impact on cross-border investments.

Tax news

JULY 25, 2022 • 2 minute read

Dutch government wants additional dividend stripping measures

The Dutch government seeks new strategies to combat dividend stripping and prevent tax avoidance, aiming for implementation by 2024.

Tax news

JUNE 10, 2022 • 1 minute read

New Luxembourg and United Kingdom tax treaty signed

Explore the implications of the new UK-Luxembourg tax treaty and its impact on investment vehicles and tax exemptions.

Tax news

MAY 24, 2022 • 2 minute read

Luxemboug fund entitled to Spanish withholding tax refund

Luxembourg fund wins refund on Spanish withholding tax due to free movement of capital, highlighting significant legal precedent.

Tax news

APRIL 14, 2022 • 1 minute read

Public consultation on common EU withholding tax system

Explore how the EU's proposed common withholding tax system aims to streamline cross-border investments and prevent tax abuse.

Tax news

APRIL 10, 2022 • 6 minute read

Finland withholding tax exemption for foreign investment funds

ECJ rules that Finland must exempt foreign investment funds from withholding tax, upholding the free movement of capital within the EU.

Tax news

APRIL 8, 2022 • 1 minute read

European Commission requests GERMANY to bring its withholding tax in line with EU law

The European Commission urges Germany to amend its withholding tax laws to ensure equal treatment for foreign charities under EU regulations.

Tax news

MARCH 14, 2022 • 1 minute read

EU parliament adopts recommendations on EU withholding tax reform

The European Parliament endorses plans to reform and simplify withholding tax systems across the EU, aiming for a standardized approach and improved cooperation among Member States.

Tax news

FEBRUARY 2, 2022 • 2 minute read

France publishes new list of public entities subject to French financial transaction tax

Discover which French public companies now meet the threshold for France's financial transaction tax with the updated list.

Tax news

JANUARY 6, 2022 • 1 minute read

European Commission urges Sweden to amend its rules on taxation of dividends to foreign public pension institutions

The European Commission challenges Sweden's dividend tax rules for foreign pension funds, citing a breach of the free movement of capital. Sweden has two months to respond.

Tax news

JANUARY 4, 2022 • 2 minute read

How to Build a Withholding Tax Recovery Process for Global Investment Portfolios

Streamline global investment tax reclaims by defining processes, clarifying roles, and ensuring efficient documentation and compliance.

Knowledge hub

DECEMBER 15, 2021 • 1 minute read

Denmark exempts foreign charities from dividend withholding tax from 2023

Starting in 2023, foreign charities will enjoy dividend tax exemptions in Denmark, following the resolution of EU infringement proceedings.

Tax news

SEPTEMBER 29, 2021 • 2 minute read

European Commission releases roadmap to a common EU-wide system for withholding tax on dividend or interest payments

Streamlining EU withholding tax: Explore the European Commission's roadmap for simplifying cross-border dividend and interest payment taxation.

Tax news

SEPTEMBER 28, 2021 • 11 seconds read

Argentina extends reduction of dividend withholding tax rate

Argentina extends its reduced dividend withholding tax rate, initially effective from January 2018, offering continued tax relief for investors.

Tax news

AUGUST 23, 2021 • 23 seconds read

New treaty between Serbia and Singapore offers exemption from Serbia dividend withholding tax for dividends to the Government of Singapore

Explore how the new Serbia-Singapore tax treaty impacts dividend withholding tax exemptions for the Singaporean government.

Tax news

JULY 27, 2021

United Arab Emirates – Austria Protocol introduces dividend tax exemption for governments and sovereign wealth funds

Discover how the new protocol between the UAE and Austria offers tax benefits for government and sovereign wealth funds.

Tax news

JUNE 15, 2021 • 2 minute read

Life insurance companies entitled to refund of French dividend withholding tax

Discover how a landmark French Supreme Court ruling entitles life insurance firms globally to reclaim withheld dividend taxes.

Tax news

MAY 28, 2021 • 2 minute read

Germany centralizes filing of free movement of capital based German dividend tax reclaims

Germany streamlines ECJ dividend tax reclaims, assigning the federal tax office as the central authority for processing, saving time and effort for foreign investors.

Tax news

MAY 26, 2021 • 36 seconds read

EU prepares for new EU wide withholding tax system

The EU plans to streamline cross-border investment by introducing a unified withholding tax system.

Tax news

APRIL 9, 2021 • 3 minute read

Dutch Supreme Court rejects ECJ withholding tax reclaim from foreign investment fund

Dutch Supreme Court denies foreign investment fund's claim for Dutch tax refund, citing no violation of EU free movement of capital rules.

Tax news

MARCH 22, 2021 • 3 minute read

Spanish Supreme Court confirmed ECJ reclaim by Norwegian sovereign wealth fund

Spanish Supreme Court upholds ECJ ruling for Norwegian SWFs, reinforcing free capital movement by mandating Spanish dividend tax refunds. Explore the case's implications for foreign investments.

Tax news

MARCH 9, 2021 • 2 minute read

European Commission formally asks Sweden and France to stop higher withholding tax to foreign pension institutions and insurance companies

EU urges Sweden and France to align dividend tax rules with EU law, ensuring fair treatment for foreign pension and insurance entities.

Tax news

FEBRUARY 3, 2021 • 17 seconds read

Netherlands and Chile sign tax treaty: 0% dividend withholding tax for pension funds

Discover how the new tax treaty between the Netherlands and Chile benefits pension funds with a 0% dividend withholding tax.

Tax news

JANUARY 14, 2021 • 4 minute read

Canadian pension fund entitled to ECJ reclaim in Spain

Spanish Supreme Court orders refund of withheld dividend tax to Canadian pension fund, setting a crucial precedent for non-EU funds. Discover the implications of this landmark ruling.

Press

JANUARY 4, 2021 • 3 minute read

Brexit creates withholding tax leakage for UK pension funds, UCITS and AIFs

Brexit impacts UK pension funds and investment funds with withholding tax challenges in the EU, as exemptions become limited. Learn how to navigate this complex tax landscape.

Tax news

DECEMBER 23, 2020 • 3 minute read

Spanish dividend withholding tax violates free movement of capital and must be refunded, says Spanish Supreme Court

Spanish Supreme Court orders refund of dividend tax, citing violation of EU's free movement of capital. Non-resident pension funds urged to file claims.

Tax news

NOVEMBER 21, 2020 • 41 seconds read

Polish withholding tax refund procedure to become less burdensome in 2021

Streamlined tax reclaim process in Poland aims to reduce the burden on foreign investors starting in 2021.

Tax news

NOVEMBER 17, 2020 • 1 minute read

New Protocol to Netherlands - Poland tax treaty introduces 0% dividend withholding tax for pension funds

Discover how the new tax treaty protocol between the Netherlands and Poland benefits pension funds with a 0% dividend withholding tax rate.

Tax news

NOVEMBER 17, 2020 • 1 minute read

Italy proposes dividend withholding tax exemption for EU collective investment funds in 2021

Italy's 2021 budget proposes a tax exemption for EU investment funds, aligning with EU court rulings on free capital movement.

Tax news

NOVEMBER 2, 2020 • 1 minute read

EC asks Belgium to stop taxing foreign insurance companies more heavily than Belgian insurance companies

The European Commission urges Belgium to align its tax policies for foreign insurance firms with EU law, challenging potential discrimination.

Tax news

OCTOBER 28, 2020 • 4 minute read

Why so much withholding tax relief remains unclaimed

Explore why billions in withholding tax relief go unclaimed annually and how automation could transform recovery processes.

Knowledge hub

OCTOBER 23, 2020 • 1 minute read

Dutch Supreme Court opens the door to ECJ reclaims in the Netherlands by foreign investment funds

Foreign investment funds can now reclaim Dutch dividend withholding tax, aligning with EU free movement of capital principles.

Tax news

OCTOBER 20, 2020 • 1 minute read

UK pension funds are losing up to GBP 250 million annually by not investing through tax transparent investment funds

UK pension funds risk losing significant income annually by avoiding tax transparent investment funds, a recent study reveals.

Tax news

SEPTEMBER 24, 2020 • 50 seconds read

ESMA recommends tax information exchange

ESMA urges the European Commission to enable financial bodies to share data with tax authorities to tackle tax fraud effectively.

Tax news

SEPTEMBER 17, 2020 • 2 minute read

Dutch government proposes changes to the dividend withholding tax on portfolio investments in domestic situations

Explore the Dutch government's proposed changes to dividend withholding tax, impacting both domestic and foreign portfolio investments.

Tax news

SEPTEMBER 16, 2020 • 46 seconds read

France releases new guidelines for dividend withholding tax exemption at source and refund procedures for foreign collective investment vehicles

Explore France's updated guidelines for dividend withholding tax exemptions and refunds for foreign investment vehicles.

Tax news

SEPTEMBER 6, 2020 • 3 minute read

South Africa public ruling on beneficial ownership for UK Authorized Contractual Scheme

Discover how the SARS ruling impacts UK investors in Authorized Contractual Schemes claiming treaty benefits in South Africa.

Tax news

JULY 24, 2020 • 3 minute read

European Commission announces plans for EU-wide system for withholding tax relief at source

Discover how the EU aims to streamline withholding tax relief across member states, enhancing investment simplicity and economic recovery.

Tax news

JULY 3, 2020 • 7 minute read

Securities lending and holding periods

Explore the complexities of securities lending, tax implications, and holding periods, and uncover strategies to optimize your investments while navigating potential tax challenges.

Knowledge hub

JUNE 18, 2020 • 5 minute read

Dutch tax treaty policy 2020 difference between collective and individual pension and withholding tax

Explore how recent Dutch tax treaty policies impact pension plans, creating distinctions in investment returns through withholding tax exemptions.

Tax news

NOVEMBER 19, 2019 • 4 minute read

ECJ ruling could further erode EU dividend tax obstacles

ECJ decision may ease dividend tax barriers for EU pension funds, potentially reshaping cross-border investment dynamics.

PressTax news

NOVEMBER 14, 2019 • 16 minute read

ECJ: German withholding tax levied from Canadian pension fund violates the EU treaty

Explore the ECJ's ruling on German withholding tax and its impact on foreign pension funds' rights under the EU treaty.

Tax news

JUNE 5, 2019 • 12 minute read

ECJ’s Attorney General: German Dividend Withholding Tax Violates Eu Treaty

The ECJ Attorney General finds German dividend withholding tax breaches EU Treaty, impacting foreign pension funds. Discover the implications for non-German investors.

Tax news

DECEMBER 20, 2018 • 5 minute read

ECJ’s AG Renders Opinion On Relationship Between Free Movement Of Capital And Eu State Aid Rules

Explore the AG's pivotal Opinion on how free movement of capital intersects with EU state aid rules in the complex A-Fonds case.

Tax news

DECEMBER 1, 2018 • 30 seconds read

Japan's 2018 new and revised tax treaties very beneficial to pension funds

Discover how Japan's 2018 tax treaties offer substantial benefits to pension funds through foreign dividend tax exemptions.

Tax news

JULY 1, 2018 • 4 minute read

Why institutional investors are leaving millions of withholding tax on the table every year.

Discover why institutional investors are missing out on millions in withholding tax relief and how new solutions are addressing this costly oversight.

Knowledge hub

JUNE 21, 2018 • 7 minute read

ECJ renders decision in Fidelity Funds case

ECJ's landmark decision on Fidelity Funds case boosts non-resident mutual funds' chances for reclaiming withholding tax across EU member states.

Tax news

JUNE 20, 2018 • 3 minute read

Investors recover millions of euro in first few months of new withholding tax reclaiming platform, Protocol

Discover how Protocol, an innovative platform by Taxology, is transforming withholding tax recovery for pension funds, reclaiming millions effortlessly.

Press

MAY 15, 2018 • 3 minute read

Protocol, A New Web-Based Solution Automating Global Withholding Tax Recovery, Launches In North America

Discover how Protocol streamlines global withholding tax recovery, saving time and costs for pension funds and investment managers in North America.

Press

MAY 11, 2018 • 29 seconds read

Dividend Withholding Tax in Spain

Navigate the complexities of Spain's 19% dividend withholding tax, recovery processes, and relief options through double tax treaties.

Knowledge hub

MAY 10, 2018 • 1 minute read

What is a Dividend Voucher?

Understand the role of a dividend voucher, a key document issued to shareholders detailing dividends and withholding tax. Discover its purpose and jurisdictional requirements.

Knowledge hub

MAY 7, 2018 • 1 minute read

Dividend Withholding Tax in Germany

Explore Germany's dividend withholding tax rates, refund options, and treaty exemptions to optimize your tax strategy.

Knowledge hub

MAY 4, 2018 • 34 seconds read

Dividend Withholding Tax in Canada

Explore Canada's dividend withholding tax, potential reductions through tax treaties, and how to secure refunds with CRA Form NR7-R.

Knowledge hub

APRIL 29, 2018 • 24 seconds read

Dividend Withholding Tax in Switzerland

Explore how Switzerland's 35% dividend withholding tax can be reduced or eliminated through double tax treaties and refund options.

Knowledge hub

APRIL 29, 2018 • 3 minute read

Dividend withholding tax: the 4 most important things to take into account

Navigate dividend withholding tax complexities with insights on liabilities, rates, double taxation, and relief options. Discover key considerations to manage these obligations effectively.

Knowledge hub

APRIL 20, 2018 • 31 seconds read

Dividend Withholding Tax in Ireland

Explore Ireland's 25% dividend withholding tax and learn about exemptions and refunds available to EU residents and countries with tax treaties.

Knowledge hub

APRIL 19, 2018 • 44 seconds read

Dividend Withholding Tax in France

Explore France's dividend withholding tax rates, potential relief through double tax treaties, and necessary forms for reclaiming excess tax withheld.

Knowledge hub

APRIL 16, 2018 • 1 minute read

Dividend Withholding Tax in Australia

Explore Australia's dividend withholding tax, its impact on foreign shareholders, and potential relief through double tax treaties.

Knowledge hub

APRIL 5, 2018 • 1 minute read

Dividend Withholding Tax in the Netherlands

Explore the Dutch dividend withholding tax, exemptions, and refund methods for tax-exempt entities and learn about critical deadlines.

Knowledge hub

APRIL 3, 2018 • 3 minute read

Dividend Withholding Tax in the United States

Explore the complexities of dividend withholding tax in the US, including how investors can secure possible reductions and navigate self-certification requirements.

Knowledge hub

APRIL 2, 2018 • 24 seconds read

Dividend Withholding Tax in the United Kingdom

Explore how the UK handles dividend withholding tax, especially for REITs, and discover potential relief options for non-residents.

Knowledge hub

MARCH 20, 2018 • 38 seconds read

Dividend withholding tax in Luxembourg

Explore Luxembourg's dividend withholding tax, its rates, exemptions, and reclaim opportunities under double tax treaties.

Knowledge hub

JANUARY 22, 2018 • 4 minute read

Netherlands publishes conditions for foreign pension funds ECJ reclaims

Discover the new guidelines for foreign pension funds claiming ECJ reclaims in the Netherlands and ensure compliance with Dutch tax exemption standards.

Tax news

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