invested and remitted to the source country’s tax administration. Source country
domestic rates vary from 10% up to 35% over the gross return of investment.
Relief from withholding tax, either at source (applied by the company paying the
dividends or interest) or by retrospective reclaims (by – or on behalf of – the
investor), is often available based on domestic law, tax treaties, the EU treaty, or
less well known legal bases. The type of relief, and the degree of relief – from a
reduction of the rate to a full exemption or refund – depends on the type of
investor, and the way in which investments are structured.
However, monetizing this tax relief means following strict and complex procedures
in the source country. And this is where the problem comes in. Within the EU, no