Operational tax risk for financial intermediaries and investors: how do you manage it?

Tax authorities across the world are becoming more aggressive in reviewing double tax treaty claims raising withholding rates in general and implementing enhanced documentation requirements for non-resident investors wishing to claim reduced rates of withholding tax under a treaty or domestic law. This is in part designed to repair fiscal shortfalls but is also a product of greater information sharing between tax authorities who have increasingly become concerned with issues of perceived tax evasion.

This enhanced level of interest by tax authorities has also begun to lead to a change of emphasis within financial institutions. Operational tax oversight and control is moving out of the primary domain of the back office into a shared space with...