Withholding Tax Study

On behalf of our asset management practice, we are delighted to welcome you to KPMG Ireland’s Withholding Tax Study in relation to corporate Irish regulated investment funds.

Withholding tax (WHT) management is attracting increased focus from directors and investors, given the potential impact on NAV for some funds. In our experience, there are instances where withholding tax relief mechanisms are not being fully utilised by funds, meaning that reclaim or relief opportunities are being overlooked – this is ultimately an opportunity foregone to increase NAV for investors. This will only become more topical in the coming years given the ECOFIN agreement on 14 May 2024 in respect of the “Faster and Safer Relief of Excess Withholding Taxes (FASTER)” Directive, which EU Member States have until the end of 2028 to transpose into domestic law (with the rules to become applicable as of January 1, 2030).

More about this study

This study analyses the WHT rates across different jurisdictions with respect to Irish regulated investment funds in order to provide a snapshot of the expected rates applicable in each country, in addition to identifying any possible scope for relief.

We have included information in respect of more than 85 countries and analysed the WHT rates applicable to interest, dividends and capital gains applicable to Irish corporate funds (ICAV and plc) based on the rules in force as of 1 January 2024. For each country, we have identified the general WHT rates based on domestic law for each type of income, supplemented by the reduced WHT rate (i.e. the possibility of reduction) and the reclaimable WHT rate (i.e. the possibility of a tax reclaim). We have also included guidance on the difficulty level of reducing and / or reclaiming WHT and indicate these levels using a traffic light system, based on our experience.

We hope you find the contents of this study useful and would be happy to discuss how we can help you maximise withholding tax efficiencies further.