Cross-border investment withholding tax a practical guide for investors and intermediaries /
This book provides a clear and concise explanation of withholding tax and how to leverage best practice to generate improved investment performance. It gives practical guidance to financial service firms and investors to help them understand the issues involved, trends and practicalities of maximizi...
| Main Author: | McGill, Ross, 1955- |
|---|---|
| Other Authors: | SpringerLink (Online service) |
| Format: | eBook |
| Language: | English |
| Published: |
Cham :
Palgrave Macmillan,
[2023]
|
| Physical Description: |
1 online resource. |
| Edition: | Second edition. |
| Series: |
Finance and capital markets.
|
| Subjects: |
Table of Contents:
- Intro
- Foreword
- Preface to the Second Edition
- Acknowledgements
- About This Book
- Contents
- About the Author
- Abbreviations
- List of Exhibits
- Part I Essentials
- 1 Introduction
- 2 Principles
- Double Tax Principle
- Jurisdictional Principle
- Transparency Principle
- Process and Procedure Principles
- Automation Principles
- Principle of Interests
- Issuers
- Intermediaries
- Advisors
- Vendors
- Investors
- Tax Administrations
- 3 Context
- Materiality
- Commercial
- Geopolitical
- Technology
- Why Should We Care?
- Non-Treaty Based Entitlements.
- Process and Procedure
- Documentation and Forms
- Proof of Income
- Corporate Governance
- 4 Variability
- Documentation
- Relationship
- Treaty
- Status
- Residency
- Authority
- Validity
- Statutes of Limitation
- Year of Income
- Types of Income
- Pro Rata Temporis
- Original Issue Discount (OID)
- Forms
- Recovery Time
- Tax Information Reporting and Audit Oversight
- 5 The Pace of Change
- Part II Operational Models
- 6 Tax Relief at Source
- 7 Quick Refunds
- 8 Standard Refunds
- ECJ Claims
- Beneficial Owners
- Financial Instruments
- The Role of Sub-Custodians.
- The Role of Investors
- Certifying Residency
- Responsibility for Accuracy
- Service Level Agreements
- The Role of Tax Authorities
- Proof of Tax Residency
- Sources of Reclaim Forms
- Receipt and Assessment of Reclaims
- Proof of Identity
- Proof of Sufferance of Double Tax
- Powers of Attorney
- Benchmarking
- Validity
- Establishing Validity
- Calculating Value
- Filling in Forms
- Getting Local Tax Authority Approval
- Filing to Foreign Tax Authorities
- The Role of Sub Custodians
- Chasing for Payment
- Refund Payments
- Crediting Client Accounts
- 9 Reporting.
- 10 Governance and Enforcement
- Part III Practical Implementations
- 11 United States of America
- Documentation
- Withholding
- Deposits
- Reporting
- NQIs
- Governance
- 12 871(m), 1446(a) and 1446(f) Withholding
- 871(m)
- CEDEARs
- 1446(a) and 1446(f)
- Operating Model Options
- Withholding QI
- Non-Withholding QI
- 13 EU Withholding Tax Code of Conduct
- The Code of Conduct
- 14 OECD Tax Relief and Compliance Enhancement
- 15 Finland
- Part IV Impacts of Tax Evasion and Fraud
- 16 FATCA
- 17 AEoI/Common Reporting Standard
- 18 DAC6
- Causes
- Purpose.
- Intermediaries
- Legal Professional Privilege
- Hallmarks
- Framework
- 19 Tax Fraud
- Denmark
- Germany
- Part V Technology
- 20 ISO Standards
- ISO15022 & ISO20022
- XBRL
- 21 Platforms
- ESP®
- MIDAS®
- Tax Compliance Toolkit{u2122}
- Investor Self Declarations{u2122}
- Adroit{u2122}
- 22 Getting Rid of Paper
- Cost
- 23 Withholding Tax on the Blockchain
- Part VI Performance
- 24 Benchmarking
- Eurobonds
- Process Efficiency
- Risk Management Benchmarks
- Proportion of Fails (PF)
- Age Debt Performance (ADP)
- Fit (F)
- Statute Risk (SR)
- RAS Efficient (RAS)
- PoA Index.