two withholding tax relief procedures are the same. Each country has its own
procedure, relief forms, statute of limitations, and its own take on what supporting
documentation should be submitted. Knowing your way around and complying
with all of these different procedures faces investors with tremendous compliance
costs. And in a worst case scenario faces them with double taxation[1] (or single
taxation where there should have been no taxation, like in the case of tax exempt
entities such as pension funds and charities), as the income is also taxed in the
investor’s country of residence.
This issue has been recognized since the beginning of this century by leading
institutions on international taxation like the OECD[2] and the European