Dividend Withholding Tax Planning Techniques: Part 1

Although there is a confounding variety of cross border dividend withholding tax planning techniques available to the modern corporate taxpayer this study has sought to identify, analyse and categorize these techniques in abstracto and, unless stated otherwise, without linking these techniques to particular countries.

Part 1 of this two-part study identifies, analyses and categorizes the so-called formal dividend withholding tax planning techniques. Part 2 identifies, analyses and categorizes the so-called substantive dividend withholding tax planning techniques. In addition, part 2 provides a framework whereby the various dividend withholding tax planning techniques can be categorized in a consistent and universal manner.