OCTOBER 6, 2026 • 18 minute read
Italy has increased the withholding tax (“WHT”) on Italian-source dividends paid to qualifying EU/EEA pension funds from 11% to 20%, with effect from 12 August 2026. The change is intended to align the rate applicable to foreign pension funds with the 20% substitute tax applicable to the investment results of Italian pension funds.
SEPTEMBER 30, 2026 • 5 minute read
Discover how PGB Pensioendiensten uses Protocol to strengthen withholding tax recovery, identify additional reclaim opportunities, and improve oversight through specialized tax expertise and data-driven insights.
SEPTEMBER 24, 2026 • 3 minute read
Protocol's data cleaning, import and reclaims matching engine has been rebuilt from the ground up - bringing more speed, more accuracy, and full transparency into every step of the process.
SEPTEMBER 17, 2026 • 16 minute read
The Court of Justice of the European Union has delivered its judgment in iShares Europe ETF (C-139/25), concerning the Spanish taxation of dividends received by a US investment fund. The case adds a new question to the CJEU's extensive case law on discriminatory withholding taxation of non-resident investment funds: can a restriction on the free movement of capital be neutralized on the ground that a foreign fund could have chosen a tax treatment in its state of residence under which it would have been able to credit the source-state tax, even though it did not make that choice?
SEPTEMBER 10, 2026 • 7 minute read
Explore Austria's dividend withholding tax rates, treaty relief mechanisms, EU exemptions, and procedures for reclaiming excess tax withheld.
AUGUST 18, 2026 • 10 minute read
Discover how MiKaDiv changes German withholding tax reclaims, and what impact it has for non-resident investors.
JULY 7, 2026 • 7 minute read
Explore the Netherlands' dividend withholding tax rates, available treaty relief, reclaim procedures, and key developments affecting non-resident investors.
JUNE 12, 2026 • 6 minute read
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.
JUNE 10, 2026 • 3 minute read
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.
JUNE 10, 2026 • 5 minute read
Italian courts have now provided strong support for the position 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 from each dividend payment, claims for 2022 dividends are expiring during 2026.
JUNE 4, 2026 • 5 minute read
This article compares dividend withholding tax regimes in the BENELUX region: Belgium, the Netherlands, and Luxembourg, covering domestic rates, treaty relief mechanisms, reclaim procedures, and key differences for cross-border investors.
MAY 27, 2026 • 6 minute read
Learn how Denmark now grants Canadian Master Trust pension funds a 0% dividend withholding tax exemption under the Canada-Denmark tax treaty.
APRIL 30, 2026 • 6 minute read
Denmark’s tax authority, SKAT, proved in the English courts that billions were paid out through invalid withholding tax refund claims connected to cum-ex trading. Yet the authority still lost one of the largest fraud cases ever heard in the English Commercial Court.
APRIL 29, 2026 • 7 minute read
Learn Belgium dividend withholding tax rates, treaty relief, and how to reclaim excess WHT. Understand procedures, deadlines, and key requirements.
MARCH 1, 2026 • 4 minute read
On 10 February 2026, the Grand Chamber of the Court of Justice of the European Union (CJEU) heard oral arguments in Case C-241/25, a potentially significant development for EU-based investors with exposure to Swedish equities. The case concerns whether Sweden can require foreign companies to recalculate their tax position under Swedish rules before reclaiming dividend withholding tax (WHT).
MARCH 1, 2026 • 7 minute read
The Dutch government’s reform of the fonds voor gemene rekening (FGR) regime continues to create uncertainty for investment funds with Dutch investors or Dutch-source income. What initially appeared to be a technical update to Dutch fund classification rules has evolved into a broader discussion about withholding tax exposure, cross-border investment structures, and the future of tax transparency in the Netherlands.
FEBRUARY 16, 2026 • 4 minute read
Accessing withholding tax exemptions in the European Union has long been a struggle of substance versus form. While EU law prohibits discrimination against non-resident investors, member states often implement "paperwork walls" that make relief technically possible but practically impossible to achieve.
JANUARY 15, 2026 • 5 minute read
This country-by-country guide provides a comprehensive overview of dividend withholding tax reclaims worldwide, helping institutional and professional investors identify reclaim opportunities, understand local requirements, and assess operational complexity in 2026.
JANUARY 8, 2026 • 4 minute read
Brazil has enacted Law 15,270/2025, reintroducing withholding tax on dividend distributions for the first time in nearly three decades. Effective 1 January 2026, the new regime has important implications for foreign institutional investors, including pension funds and sovereign entities.
DECEMBER 22, 2025 • 5 minute read
A Spanish TEAC ruling shows how U.S. group trusts must prove beneficiary-level residence to obtain Spain–U.S. treaty withholding tax relief.
DECEMBER 11, 2025 • 8 minute read
Explore Luxembourg's dividend withholding tax, its rates, exemptions, and reclaim opportunities under double tax treaties.
DECEMBER 8, 2025 • 4 minute read
Belgium’s latest adjustments to the withholding tax (WHT) regime has sparked substantial debate among tax practitioners when it comes to the increase of the reduced rate on dividends under the VVPRbis mechanism.
DECEMBER 7, 2025 • 3 minute read
The Dutch State Secretary for Finance has released an updated Fund Decree (2 December 2025), offering new guidance on how Dutch tax law treats investment funds, particularly those organized as Dutch or foreign limited partnerships.
NOVEMBER 5, 2025 • 6 minute read
Explore France's dividend withholding tax rates, potential relief through double tax treaties, and necessary forms for reclaiming excess tax withheld.
OCTOBER 1, 2025 • 6 minute read
Learn how to reclaim German dividend withholding tax, navigate anti-abuse rules, and prepare for MiKaDiv’s 2027 digital overhaul.
AUGUST 26, 2025 • 5 minute read
In a decisive judgment rendered on 30 April 2025 in Finanzamt für Großbetriebe v. Franklin Mutual Series Funds – Franklin Mutual European Fund (C-602/23), the Court of Justice of the European Union (CJEU) provided clarity on the treatment of foreign investment funds under Austrian withholding tax law.
AUGUST 20, 2025 • 4 minute read
Explore how Switzerland's 35% dividend withholding tax can be reduced or eliminated through double tax treaties and refund options.
AUGUST 1, 2025 • 3 minute read
Germany’s Federal Fiscal Court (BFH) has issued a landmark judgment on one of the key legal questions behind cum-cum transactions: who economically owned the shares during the dividend period?
JULY 22, 2025 • 3 minute read
In March 2025, the United States and Denmark finalized a Competent Authority Arrangement (CAA) clarifying which pension entities or arrangements qualify under “pension fund” status in order to qualify for treaty benefits under Article 10(3)(c) of the 1999 Denmark–U.S. tax treaty.
JULY 11, 2025 • 4 minute read
On 9 July 2025, the Polish Ministry of Finance published binding tax clarifications (Objaśnienia podatkowe) on the application of the “beneficial owner” clause to withholding tax (WHT) relief. These explanationsmark the first authoritative statement of Poland’s BO doctrine.
JUNE 24, 2025 • 4 minute read
Discover how Section 899 impacts foreign investors with surtaxes up to 50%. Learn which jurisdictions are affected and how to plan ahead.
MAY 29, 2025 • 2 minute read
The classification of claimants in a withholding tax reclaim process is a critical first step. Whether a claimant is a fund vehicle, an investor, or both determines the documentation required and the success of the claim. Misclassification can lead to over- or under-withholding, incorrect filings, and ultimately failed reclaims.
MAY 8, 2025 • 2 minute read
Optimizing and managing withholding tax for global public equities investment portfolios is complex and time-consuming. A well-structured process can help ensure timely collection of data and efficient tax reclaims, while minimizing unnecessary communication and resource strain among stakeholders.
MAY 8, 2025 • 4 minute read
As foreign investments in South Korea grow, understanding the nuances of dividend withholding tax (WHT) becomes increasingly critical for multinational corporations and institutional investors.
APRIL 22, 2025 • 4 minute read
Italy’s Supreme Court affirms the look-through approach for WHT exemptions, clarifying that beneficial ownership—not form—drives eligibility for EU-based investors.
APRIL 16, 2025 • 2 minute read
Taiwan's MOF extends the application period for tax treaty benefits from 5 to 10 years, enhancing consistency and fairness for nonresident taxpayers.
MARCH 25, 2025 • 4 minute read
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.
MARCH 18, 2025 • 3 minute read
The Swedish court's ruling in the KEVA case could expand pension fund claims, challenging Sweden's withholding tax policies.
FEBRUARY 18, 2025 • 2 minute read
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 rules Biscay's tax laws breach Article 63 TFEU, impacting cross-border investments and favoring resident companies.
JANUARY 8, 2025 • 2 minute read
Explore key 2024 EU tax court decisions on withholding tax reclaims, including major directives and landmark rulings impacting foreign investment funds.
DECEMBER 17, 2024 • 2 minute read
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.
NOVEMBER 12, 2024 • 7 minute read
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.
OCTOBER 4, 2024 • 5 minute read
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.
SEPTEMBER 13, 2024 • 6 minute read
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.
AUGUST 26, 2024 • 6 minute read
Explore the complexities of cross-border taxation and discover key insights from the landmark L Fund case.
AUGUST 1, 2024 • 4 minute read
CJEU rules Swedish tax law violates Article 63 TFEU by unfairly taxing non-resident pension funds, restricting free movement of capital.
JULY 29, 2024 • 2 minute read
The EU targets Dutch tax practices to promote fair investment across member states, highlighting the importance of equitable financial policies.
JUNE 27, 2024 • 3 minute read
Discover effective strategies to address EU national courts' non-compliance with CJEU rulings on free movement of capital and withholding tax.
MAY 16, 2024 • 4 minute read
EU Council endorses new rules to expedite double taxation relief, boost cross-border investments, and fight tax fraud.
APRIL 25, 2024 • 3 minute read
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
Explore the implications of the CJEU Attorney General's opinion on tax discrimination and capital movement in the EU.
MARCH 7, 2024 • 8 minute read
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.
FEBRUARY 29, 2024 • 6 minute read
Polish court sides with Canadian fund on tax refund, highlighting EU law's impact on international tax equity.
FEBRUARY 12, 2024 • 6 minute read
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.
FEBRUARY 2, 2024 • 6 minute read
Explore how OECD's Pillar Two reshapes international taxation, impacting institutional investors beyond multinational enterprises.
DECEMBER 15, 2023 • 5 minute read
Dutch tax authorities reinterpret rules, affecting foreign pension funds' dividend withholding tax reclaims. Disputes arise over statute of limitations and objective comparability.
SEPTEMBER 20, 2023 • 3 minute read
On September 19, the Dutch government presented its 2024 Budget Plan, introducing new measures against dividend stripping.
JUNE 21, 2023 • 7 minute read
Explore the European Commission's recent proposal for a unified EU withholding tax system, featuring a digital tax residence certificate and streamlined relief procedures.
DECEMBER 16, 2022 • 4 minute read
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.
DECEMBER 14, 2022 • 2 minute read
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.
SEPTEMBER 29, 2022 • 1 minute read
Denmark's new tax proposal may challenge EU free movement rules, applying a 22% dividend tax on foreign government investors.
SEPTEMBER 21, 2022 • 4 minute read
Dutch tax authorities initiate a large-scale review to reclaim millions in ECJ refunds from foreign pension funds, questioning their comparability to domestic counterparts.
SEPTEMBER 14, 2022 • 3 minute read
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.
SEPTEMBER 9, 2022 • 3 minute read
Taiwan simplifies tax processes for Foreign Institutional Investors, aligning with eco-friendly trends and enhancing market development.
AUGUST 31, 2022 • 3 minute read
Uncover the mechanics and implications of cum-ex transactions, a complex tax fraud scheme impacting European economies.
AUGUST 2, 2022 • 2 minute read
Explore the European Commission's summary report on the proposed EU-wide withholding tax system and its potential impact on cross-border investments.
JULY 25, 2022 • 2 minute read
The Dutch government seeks new strategies to combat dividend stripping and prevent tax avoidance, aiming for implementation by 2024.
JUNE 10, 2022 • 1 minute read
Explore the implications of the new UK-Luxembourg tax treaty and its impact on investment vehicles and tax exemptions.
MAY 24, 2022 • 2 minute read
Luxembourg fund wins refund on Spanish withholding tax due to free movement of capital, highlighting significant legal precedent.
APRIL 14, 2022 • 1 minute read
Explore how the EU's proposed common withholding tax system aims to streamline cross-border investments and prevent tax abuse.
APRIL 10, 2022 • 6 minute read
ECJ rules that Finland must exempt foreign investment funds from withholding tax, upholding the free movement of capital within the EU.
APRIL 8, 2022 • 1 minute read
The European Commission urges Germany to amend its withholding tax laws to ensure equal treatment for foreign charities under EU regulations.
MARCH 14, 2022 • 1 minute read
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.
FEBRUARY 2, 2022 • 2 minute read
Discover which French public companies now meet the threshold for France's financial transaction tax with the updated list.
JANUARY 6, 2022 • 1 minute read
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.
JANUARY 4, 2022 • 2 minute read
Streamline global investment tax reclaims by defining processes, clarifying roles, and ensuring efficient documentation and compliance.
DECEMBER 15, 2021 • 1 minute read
Starting in 2023, foreign charities will enjoy dividend tax exemptions in Denmark, following the resolution of EU infringement proceedings.
SEPTEMBER 29, 2021 • 2 minute read
Streamlining EU withholding tax: Explore the European Commission's roadmap for simplifying cross-border dividend and interest payment taxation.
SEPTEMBER 28, 2021 • 11 seconds read
Argentina extends its reduced dividend withholding tax rate, initially effective from January 2018, offering continued tax relief for investors.
AUGUST 23, 2021 • 23 seconds read
Explore how the new Serbia-Singapore tax treaty impacts dividend withholding tax exemptions for the Singaporean government.
JULY 27, 2021
Discover how the new protocol between the UAE and Austria offers tax benefits for government and sovereign wealth funds.
JUNE 15, 2021 • 2 minute read
Discover how a landmark French Supreme Court ruling entitles life insurance firms globally to reclaim withheld dividend taxes.
MAY 28, 2021 • 2 minute read
Germany streamlines ECJ dividend tax reclaims, assigning the federal tax office as the central authority for processing, saving time and effort for foreign investors.
MAY 26, 2021 • 36 seconds read
The EU plans to streamline cross-border investment by introducing a unified withholding tax system.
APRIL 9, 2021 • 3 minute read
Dutch Supreme Court denies foreign investment fund's claim for Dutch tax refund, citing no violation of EU free movement of capital rules.
MARCH 22, 2021 • 3 minute read
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.
MARCH 9, 2021 • 2 minute read
EU urges Sweden and France to align dividend tax rules with EU law, ensuring fair treatment for foreign pension and insurance entities.
FEBRUARY 3, 2021 • 17 seconds read
Discover how the new tax treaty between the Netherlands and Chile benefits pension funds with a 0% dividend withholding tax.
JANUARY 14, 2021 • 4 minute read
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.
JANUARY 4, 2021 • 3 minute read
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.
DECEMBER 23, 2020 • 3 minute read
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.
NOVEMBER 21, 2020 • 41 seconds read
Streamlined tax reclaim process in Poland aims to reduce the burden on foreign investors starting in 2021.
NOVEMBER 17, 2020 • 1 minute read
Discover how the new tax treaty protocol between the Netherlands and Poland benefits pension funds with a 0% dividend withholding tax rate.
NOVEMBER 17, 2020 • 1 minute read
Italy's 2021 budget proposes a tax exemption for EU investment funds, aligning with EU court rulings on free capital movement.
NOVEMBER 2, 2020 • 1 minute read
The European Commission urges Belgium to align its tax policies for foreign insurance firms with EU law, challenging potential discrimination.
OCTOBER 28, 2020 • 4 minute read
Explore why billions in withholding tax relief go unclaimed annually and how automation could transform recovery processes.
OCTOBER 23, 2020 • 1 minute read
Foreign investment funds can now reclaim Dutch dividend withholding tax, aligning with EU free movement of capital principles.
OCTOBER 20, 2020 • 1 minute read
UK pension funds risk losing significant income annually by avoiding tax transparent investment funds, a recent study reveals.
SEPTEMBER 24, 2020 • 50 seconds read
ESMA urges the European Commission to enable financial bodies to share data with tax authorities to tackle tax fraud effectively.
SEPTEMBER 17, 2020 • 2 minute read
Explore the Dutch government's proposed changes to dividend withholding tax, impacting both domestic and foreign portfolio investments.
SEPTEMBER 16, 2020 • 46 seconds read
Explore France's updated guidelines for dividend withholding tax exemptions and refunds for foreign investment vehicles.
SEPTEMBER 6, 2020 • 3 minute read
Discover how the SARS ruling impacts UK investors in Authorized Contractual Schemes claiming treaty benefits in South Africa.
JULY 24, 2020 • 3 minute read
Discover how the EU aims to streamline withholding tax relief across member states, enhancing investment simplicity and economic recovery.
JULY 3, 2020 • 7 minute read
Explore the complexities of securities lending, tax implications, and holding periods, and uncover strategies to optimize your investments while navigating potential tax challenges.
JUNE 18, 2020 • 5 minute read
Explore how recent Dutch tax treaty policies impact pension plans, creating distinctions in investment returns through withholding tax exemptions.
NOVEMBER 19, 2019 • 4 minute read
ECJ decision may ease dividend tax barriers for EU pension funds, potentially reshaping cross-border investment dynamics.
NOVEMBER 14, 2019 • 16 minute read
Explore the ECJ's ruling on German withholding tax and its impact on foreign pension funds' rights under the EU treaty.
JUNE 5, 2019 • 12 minute read
The ECJ Attorney General finds German dividend withholding tax breaches EU Treaty, impacting foreign pension funds. Discover the implications for non-German investors.
DECEMBER 20, 2018 • 5 minute read
Explore the AG's pivotal Opinion on how free movement of capital intersects with EU state aid rules in the complex A-Fonds case.
DECEMBER 1, 2018 • 30 seconds read
Discover how Japan's 2018 tax treaties offer substantial benefits to pension funds through foreign dividend tax exemptions.
JULY 1, 2018 • 4 minute read
Discover why institutional investors are missing out on millions in withholding tax relief and how new solutions are addressing this costly oversight.
JUNE 21, 2018 • 7 minute read
ECJ's landmark decision on Fidelity Funds case boosts non-resident mutual funds' chances for reclaiming withholding tax across EU member states.
JUNE 20, 2018 • 3 minute read
Discover how Protocol, an innovative platform by Taxology, is transforming withholding tax recovery for pension funds, reclaiming millions effortlessly.
MAY 15, 2018 • 3 minute read
Discover how Protocol streamlines global withholding tax recovery, saving time and costs for pension funds and investment managers in North America.
MAY 11, 2018 • 29 seconds read
Navigate the complexities of Spain's 19% dividend withholding tax, recovery processes, and relief options through double tax treaties.
MAY 10, 2018 • 1 minute read
Understand the role of a dividend voucher, a key document issued to shareholders detailing dividends and withholding tax. Discover its purpose and jurisdictional requirements.
MAY 4, 2018 • 34 seconds read
Explore Canada's dividend withholding tax, potential reductions through tax treaties, and how to secure refunds with CRA Form NR7-R.
APRIL 29, 2018 • 3 minute read
Navigate dividend withholding tax complexities with insights on liabilities, rates, double taxation, and relief options. Discover key considerations to manage these obligations effectively.
APRIL 20, 2018 • 31 seconds read
Explore Ireland's 25% dividend withholding tax and learn about exemptions and refunds available to EU residents and countries with tax treaties.
APRIL 16, 2018 • 1 minute read
Explore Australia's dividend withholding tax, its impact on foreign shareholders, and potential relief through double tax treaties.
APRIL 3, 2018 • 3 minute read
Explore the complexities of dividend withholding tax in the US, including how investors can secure possible reductions and navigate self-certification requirements.
APRIL 2, 2018 • 24 seconds read
Explore how the UK handles dividend withholding tax, especially for REITs, and discover potential relief options for non-residents.
JANUARY 22, 2018 • 4 minute read
Discover the new guidelines for foreign pension funds claiming ECJ reclaims in the Netherlands and ensure compliance with Dutch tax exemption standards.
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