Dividend arbitrage: withholding tax refund claims

In this article we examine some of the recent actions taken by tax and other authorities in the context of withholding tax (WHT) claims in relation to dividend arbitrage and similar arrangements. We consider how these authorities are widening their enforcement net and consider what might be expected in the near future.

 

Civil and criminal investigations in Germany other European countries and the US have dramatically increased in recent times particularly in relation to WHT claims concerning historic dividend arbitrage transactions...