Cross-border income (e.g. dividends and interest) is often subject to withholding tax in the source state. However, according to the world income principle, investors are at the same time liable to tax on this income in their state of residence.

The aim must be to avoid a double tax burden in both states.

Double taxation agreements (DTAs) and European law offer numerous possibilities for avoiding double taxation and optimising the existing tax burden. The ECJ and the EFTA Court have, among other things, declared the withholding tax collection practices of various EU states to be not in conformity with European law in the court rulings of Santander, Aberdeen Finnivest and Fokus Bank.

Our Services

With the international KPMG network, we offer investment funds, pension institutions, business entities, other institutional investors and private investors a comprehensive range of services for EU-based withholding tax refund claims as well as refund procedures under DTAs.

Our offer, using the building block approach, includes comprehensive support from the origination of the withholding tax burden to the validation of the prospects of success in a given case (taking into account possible limitation periods), the preparation, review and submission of refund applications, and the consideration of refund payments.

Furthermore, we are happy to assist with the application for advance exemptions. Pre-exemption procedures can minimise the administrative burden and thus reduce the cost of optimal withholding.

Our services are already used by major German and foreign asset managers, insurers and capital management companies.