Book a meeting
Insights

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.

New and revised tax treaties with the a number of European countries entitle Japanese pension funds to a full exemption or refund of the foreign dividend withholding tax paid.

In 2018, Japan has concluded many new and revised tax treaties.

The new and revised tax treaties with the following countries entitle Japanese pension funds to a full exemption or refund of the foreign dividend withholding tax paid in those countries (and vice versa): Spain, Iceland, Lithuania, Denmark, Estonia, Austria, Russia, Belgium.

The exemption and refund provisions enter into effect as of 1 January 2019 for all of these treaties, except for Spain and Belgium which at this time do not have a known effective date yet.

Jeroen van der Wal

Founder and CEO

Topics

Unlock your 

withholding tax recovery potential

Get in touch and see for yourself how you can take control and optimize your withholding tax returns

Insights you might also like

JUNE 12, 2026 • 6 minute read

What Delegated Regulation (EU) 2026/110 Actually Says About FASTER's Reach

Delegated Regulation (EU) 2026/110 has resolved the critical open question in the FASTER Directive: which EU member states must operate under the new fast-track withholding tax framework, and which can stay outside it. The answer will define the operational landscape for institutional investors and custodians from 1 January 2030 onwards.

Tax news

JUNE 10, 2026 • 3 minute read

Dutch Dividend Withholding Tax Refund for Unit-Linked Insurers: Court of Appeal 's-Hertogenbosch

The Court of Appeal of 's-Hertogenbosch has ordered the Dutch tax authorities to refund approximately €53.8 million in dividend withholding tax to a UK-resident unit-linked insurer, ruling that EU free movement of capital principles override the domestic treatment that left the insurer bearing a 15% withholding tax that a comparable Dutch company would never have paid. The decision clarifies the beneficial ownership analysis for unit-linked structures and sets out the conditions under which foreign insurers can pursue similar refund claims.

Tax news

JUNE 10, 2026 • 4 minute read

Italy's 1.2% Dividend WHT Reclaim Window Is Closing for Non-Resident Investors

Italian courts have now confirmed that non-resident corporate investors can reclaim Italian dividend withholding tax where it exceeded the 1.2% effective burden available to comparable Italian companies. With the 48-month limitation period running, claims for 2022 dividends are expiring during 2026.

Tax news