During the course of October, WTax attended two conferences hosted by Hansuke Consulting: Operational Taxes for Investment Firms, and the Financial Services Tax Conference: Taxation in Times of Crisis. Two significant themes emerged from the insightful discussions held, namely, the evolution of the taxation landscape, and trust in the end-to-end taxation system. With gratitude to ..read more

In the case A SCPI v. Finland (C-342/20), a decision on 7 April 2022 by the Court of Justice of the European Union (CJEU) found that Finnish legislation, which exempted contractual investment funds from paying income tax, while comparable corporate foreign investment funds were subject to income tax, is contrary to EU Law. The Applicant’s ..read more

The Provincial Tax Court of Pescara issued a judgement on 7 February 2022 (Decision No. 49). The judgement established that a Luxembourg SICAV (Société d’investissement à Capital Variable) in accordance with the Directive 2009/65/EC of the European Parliament (“UCITS Directive”) is eligible for a full refund of Italian withholding taxes levied on dividends. The judgement’s ..read more

Historic Treatment of Foreign Sourced Income From 2004 until 1 January 2022, Foreign Sourced Income (“FSI”) received in Malaysia by Malaysian taxpayers was exempt from income tax under Paragraph 28, Schedule 6 of the Income Tax Act, 1967, apart from a resident company carrying on the business of banking, insurance or sea or air transport ..read more

CJEU Advocate General Issues Opinion on Finnish Tax Exemption Relating to Investment Funds On 6 October 2021, the Advocate General of the Court of Justice of the European Union (CJEU) issued an opinion on case C-342/20 Veronsaajien oikeudenvalvontayksikkö (Exonération des fonds d’investissement contractuels) pertaining to Finland’s tax-exemption regime for contractual investment funds. The Advocate General ..read more

WHT can be as high as 35% when investing internationally, which results in a material impact on investment performance. In some instances, WHT recovery can increase dividend yields by up to 50 basis points. To compile and submit a successful WHT claim, information and documentation need to be sourced from the underlying investor, financial intermediaries ..read more

Understanding the Basics of Double Taxation on Investment Income. Put simply, double taxation occurs when two countries tax the same income ..read more

Withholding tax on investment income is undoubtedly one of these certainties, but the industry is on the cusp of momentous shifts in the way taxes are levied, recovered and tracked ..read more

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 ..read more

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 ..read more