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WTax


Julia Bricker


05 Feb 2025

Julia Bricker, global managing director at WTax, talks to John Savage about the emerging trends and regulatory developments impacting the withholding tax landscape

Image: WTax
How are advancements in AI and automation technologies reshaping the landscape of withholding tax compliance? What specific tasks within the withholding tax process are most amenable to automation, and what are the potential benefits and risks?

Advancements in AI and automation are transforming withholding tax functions by streamlining processes that were traditionally time-intensive and manual. Key tasks such as document processing, data validation, and claim submission are particularly suited to automation.

We have embraced these advancements by integrating automation into our processes, including direct connectivity with tax authority portals across multiple jurisdictions, with more underway. Supported by AI-powered optical character recognition (OCR), WTax’s platform processes tens of thousands of documents within seconds, significantly reducing manual effort and enhancing accuracy. This approach reduces administrative workloads, accelerates recovery timelines, and ensures robust quality assurance through AI-driven validation.

However, automation carries risks, and we still approach all AI related output with caution, ensuring that our quality and compliance controls and standards are adhered to. Claims requiring nuanced legal analysis or discretionary rulings, such as those involving European Court of Justice (ECJ) cases must be approached carefully.

Relying solely on technology in such cases could result in errors or missed opportunities for optimal recovery. By combining advanced automation with the specialised knowledge of its lawyers, certified public accountants (CPAs) and tax experts, we mitigate this risk, ensuring even the most intricate claims are managed with precision and care.

As tax treaties continue to evolve, what are the key challenges faced by asset servicing firms in ensuring accurate withholding tax treatment across different jurisdictions? How can firms effectively monitor changes in tax treaty provisions and their implications for their clients’ portfolios?

The diversity in how tax authorities interpret and apply treaties presents a significant challenge to ensuring accurate withholding tax treatment across jurisdictions. Variations in documentation requirements, filing deadlines, and procedural practices can also lead to inconsistencies that directly affect portfolio returns. Staying ahead of these complexities requires operational agility and access to accurate information.

Asset servicing firms often partner with specialists like WTax to address these challenges. Our proprietary tools, such as our rules engine, help firms navigate treaty complexities and other reclaim mechanisms by identifying optimal recovery paths. These tools are continuously updated to reflect the latest developments in tax practices. To stay informed, our technical team actively monitors tax legislation and procedural updates through trusted resources like IBFD and LexisNexis, engages in international tax forums, and leverages its strong relationships with tax authorities and over 150 custodians globally.

What are the essential features and functionalities of a robust tax technology solution for withholding tax compliance? How can firms effectively integrate tax technology into their existing operations to streamline processes and enhance data accuracy?

Managing withholding tax compliance requires technology that simplifies complexity. A robust solution must not only address immediate needs like document processing and claim submissions but also adapt to shifting regulations and data requirements across jurisdictions. WTax’s technology exemplifies the essential features and functionalities of a robust tax technology solution for withholding tax compliance, leveraging advanced capabilities needed for modern tax recovery.

Our proprietary platform combines:

Precision: AI-powered tools ensure every claim is evaluated against jurisdiction-specific tax rules, maximising recovery opportunities.

Efficiency: Automation processes to reconcile documentation needed in the claim process.

Transparency: A customisable reporting portal allows stakeholders to monitor every stage of the process in real time.

Collaboration: Seamless integration with tax authority systems in multiple jurisdictions ensures compliance with evolving regulations, with further expansions underway.

Effective integration requires a deliberate approach. By working with an outsourced, technology-driven expert, firms can ensure a smooth adoption process, benefiting from tailored solutions that address specific operational challenges.

What are the key regulatory trends and developments that are impacting the withholding tax landscape? How are increased regulatory scrutiny and reporting requirements affecting the operational burden on asset servicing firms?

Tax authorities are increasingly scrutinising withholding tax claims, driven by global initiatives like the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project, which aims to enhance transparency and combat tax avoidance. This has led to a rise in queried claims, with jurisdictions like Switzerland now requesting further information for a significant proportion of reclaim applications. Tax offices often require detailed supporting documentation to validate reclaim entitlements, including proof of beneficial ownership and clarity on trading activities around dividend entitlement dates​​.

These developments have placed a significant operational burden on firms, requiring them to implement systems capable of efficiently managing documentation, addressing discrepancies, and responding to technical queries if they want to ensure that no reclaims are forfeited.

We address these challenges by offering a query management service that includes analysing rejection reasons, coordinating documentation, and drafting technical responses.

With active query cases in over 20 jurisdictions, WTax ensures that clients’ claims are managed effectively and in compliance with local requirements​​.

Another key development is the European Commission’s proposed Faster and Safer Tax Excess Refund (FASTER) Directive, which seeks to streamline withholding tax relief procedures across EU member states.

The directive was adopted by the Council of the EU on 10 December 2024, marking a significant step toward harmonising tax procedures within the EU. As it progresses toward implementation, firms must prepare to align with its digital requirements to take advantage of the efficiency gains it offers.

How are global economic trends, such as interest rate fluctuations and inflation, influencing withholding tax regimes? What are the potential implications of geopolitical tensions and trade disputes on cross-border tax flows?

Economic trends such as interest rate changes and inflation can influence the dynamics of withholding tax recovery.

Higher interest rates often correspond with increased bond yields and interest payments, affecting the volume and value of payments subject to withholding tax. Inflation may lead to fiscal policy adjustments, with some governments focusing more heavily on tax enforcement to protect revenue streams.

Geopolitical tensions, like the Russia-Ukraine conflict, add further complexity. The termination of the Russia-Ukraine tax treaty in 2023 is one example of how geopolitical events can disrupt established tax agreements, directly impacting withholding tax rates and recovery processes.

Navigating these challenges requires flexibility and adaptability to evolving economic and geopolitical conditions.

What are the emerging trends and challenges that are likely to shape the future of withholding tax? How can firms prepare for the increasing complexity of tax rules and regulations in a globalised economy?

The future of withholding tax will be shaped by trends such as regulatory harmonisation, digitalisation, as well as increased scrutiny. Initiatives like the EU’s FASTER Directive aim to streamline cross-border tax processes, while tax authorities worldwide are increasingly adopting automated systems requiring electronic submissions, creating challenges for firms to adapt.

For example, Germany’s transition to a digital portal in 2023 and the introduction of its bulk submission interface (DIP.KaFE) in 2024 illustrate how regulatory shifts can disrupt traditional processes. The initial shift caused significant delays across the industry, though WTax leveraged Robotic Process Automation (RPA) to ensure uninterrupted filings.

As one of the only providers to file continuously during this period, we set the benchmark for adapting to tax authority digitalisation.

As illustrated, the increasing complexity of tax rules and regulations in a globalised economy demand agility and precision. To address this, WTax has chosen to keep its technology development in-house.

Dr. Ashley Gritzman, WTax’s chief technology officer, explains: “Maintaining full ownership of this critical aspect enables us to adapt rapidly to industry changes and maximise the benefits of emerging technologies like AI.”

This strategy allows WTax to address jurisdiction-specific regulations and swiftly update our proprietary platform to meet the challenges of an evolving global tax landscape with precision and efficiency.

How can asset servicing firms ensure the accuracy and completeness of the data used for withholding tax calculations and reporting? What are the best practices for data governance and management in the context of withholding tax?

Ensuring the accuracy and completeness of data is critical for effective withholding tax calculations and reporting, especially under increasing scrutiny from tax authorities.

Asset servicing firms should implement robust data governance practices that focus on end-to-end validation, auditability, and adaptability to jurisdiction-specific requirements.

WTax addresses these challenges through a five-step quality assurance framework that balances automation and human oversight. This process includes three automated validation phases powered by AI to identify and resolve discrepancies, followed by two manual review stages conducted by data analysts to ensure compliance with local tax regulations.

By combining technology-driven efficiency with expert review, we ensure all claims are accurate, complete, and able to withstand regulatory scrutiny.

Adopting similar layered validation systems, maintaining detailed audit trails, and ensuring seamless data integration across workflows are essential best practices for firms managing withholding tax processes. These measures not only enhance compliance but also streamline reporting and improve overall operational efficiency.

How are ESG considerations influencing the design and implementation of withholding tax regimes? What are the potential tax implications of sustainable investing strategies and green finance initiatives?

ESG principles are increasingly shaping investment strategies, requiring institutional investors and asset managers to align their activities with governance, social, and environmental objectives. Reclaiming withholding tax is a critical element of ESG-aligned strategies, and efficient recovery maximizes portfolio returns while upholding fiduciary responsibilities, ensuring that no funds are forfeited unnecessarily.

Withholding tax recovery also reflects key governance principles by enhancing transparency and accountability — core components of ESG frameworks. By recovering funds efficiently, investors can reinvest into sustainable assets, directly contributing to ESG goals.

Firms must ensure that their tax recovery processes are robust and compliant with jurisdiction-specific requirements to maintain alignment with ESG objectives. WTax supports ESG-aligned asset management by streamlining tax recovery processes and ensuring governance standards are upheld throughout the recovery lifecycle.
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