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Corridors we are building first
India ↔ United Arab Emirates A regional hub in the UAEIndia ↔ Saudi Arabia A Saudi entity for government workUAE ↔ United Kingdom A UK subsidiary
24 corridors
India ↔ United Arab EmiratesIndia ↔ Saudi ArabiaChina ↔ Southeast AsiaUnited Kingdom ↔ GCCGermany ↔ GCCUnited States ↔ MexicoUnited States ↔ Latin AmericaEurope ↔ AfricaJapan ↔ Southeast AsiaSingapore ↔ IndiaGCC ↔ AfricaChina ↔ AfricaChina ↔ GCCIndia ↔ AfricaEurope ↔ IndiaNordics ↔ GCCSouth Korea ↔ GCCUnited States ↔ BrazilUnited States ↔ Caribbean & Central AmericaAustralia ↔ Southeast AsiaUAE ↔ EuropeUAE ↔ United KingdomSaudi Arabia ↔ United StatesIndia ↔ United States
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01 · Before signatureBefore You Sign™Get the dispute clause, governing law, seat, notices and escalation steps right while the contract can still change.02 · A dispute is emergingBefore You Arbitrate™Test the claim or the defence, the evidence, the exposure and the settlement options before committing to formal proceedings.03 · A binding decision is neededArbitrationStart, answer or run an administered arbitration under the UNIONE™ Rules, with procedure sized to the value, urgency and evidence.04 · Before enforcementBefore You Enforce™Plan recognition, assets, jurisdiction and security, including State and State-owned parties, before committing to enforcement.
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Cases · Tax, finance & assurance · Tax assessments, disputes & management

Bring investment returns home tax-efficiently

We're being taxed twice on returns from abroad. Can we fix it?

WONE Global reviews treaty relief, holding structure and filings in both countries, reclaims tax where possible and sets a route that avoids the problem in future.

Bring a requirement →Ask WONE first

Countries in the typical case United Kingdom · India · Brazil · South Africa · Indonesia

The situation

What is happening

Dividends, interest or gains from an investment abroad are being taxed twice or trapped.

What is at stake

Double tax and trapped cash steadily erode the return the investment was made for.

Who faces this

  • Corporations
  • Mid-sized companies
  • Private clients and families

A scenario

Parent companyCorporation · from United Kingdom · in India, Brazil, South Africa and 1 more

It receives dividends from subsidiaries in four countries with different withholding taxes.

Where it ends Less tax lost on the way home.

A representative scenario of the work WONE Global coordinates, not a specific client’s matter.

Also asked as “Double taxation on dividends”“Withholding tax relief under a treaty”“We need to review the tax consequences of dividends”“We need treaty analysis before paying foreign dividends”

The solution

How WONE Global handles it

WONE Global reviews treaty relief, holding structure and filings in both countries, reclaims tax where possible and sets a route that avoids the problem in future.

Usually led by Tax and structuring, with Payments and currency, Treasury and funding and Accounting and annual filings.

Step by step, in the scenario

  1. Week 1Treaty rates and forms reviewed.
  2. Week 2Refunds claimed where overpaid.
  3. Week 3Forms put in place.
  4. ThenAnnual check.

Timings are typical. They depend on the countries, the authorities involved and how quickly documents are available.

Decisions

The decisions involved

  1. 01Which treaty rates apply and what proof is needed
  2. 02Whether the holding structure still qualifies for relief
  3. 03Repatriation route: dividend, loan repayment, capital reduction or royalty

Outcomes

What you receive

  • Withholding tax relief claimed
  • A repatriation plan
  • Refunds of excess tax where available

This is a general guide. Your WONE Global professional confirms the work, timing and fees for your markets before anything starts.

Services

The services involved

One area of expertise usually leads; the others move with it. WONE Global keeps them connected across every country involved.

  1. Usually leadsTax and structuring17 markets with a named lead→
  2. Often involvedPayments and currencyArranged on request→
  3. Often involvedTreasury and funding1 market with a named lead→
  4. Often involvedAccounting and annual filings7 markets with a named lead→

Who handles it

Tax and structuring, market by market

The status of the lead service in the markets that matter for this case. A named WONE Global Partner acts under their own licence; where none is in place yet, WONE Global confirms availability before anything else.

  1. Indiain the typical case WONE Global Partner Sandeep Gupta · Managing Partner Brief this Partner →
  2. Brazilin the typical case On request Availability confirmed before any work begins Bring a requirement →
  3. Indonesiain the typical case On request Availability confirmed before any work begins Bring a requirement →
  4. South Africain the typical case On request Availability confirmed before any work begins Bring a requirement →
  5. United Kingdomin the typical case On request Availability confirmed before any work begins Bring a requirement →
  6. Austria WONE Global Partner Dr. Rosam Karl J. · Managing Director Brief this Partner →
  7. Cameroon WONE Global Partner Edmond Christian AKOA MBALLA · Founder & Managing Partner Brief this Partner →
  8. Colombia WONE Global Partner Katherin Diaz Velilla · Co-Founder Brief this Partner →
  9. Ecuador WONE Global Partner Mauro Tejada Ramon · Tax & Legal Partner Brief this Partner →
  10. Germany WONE Global Partner Ulrike Berner, MBA · Managing Partner Brief this Partner →
  11. Hong Kong WONE Global Partner Yvonne Chow · Partner Brief this Partner →
  12. Ireland WONE Global Partner Kevin McSharry · Managing Director Brief this Partner →
  13. Italy WONE Global Partner Alessandro Dagnino · Managing Partner Brief this Partner →
  14. Kenya WONE Global Partner Farheen Khandwalla · Tax and Business Process Outsourcing Partner Brief this Partner →
  15. Panama WONE Global Partner Ebrahim Asvat K. · Managing Partner Brief this Partner →
  16. Rwanda WONE Global Partner Lilianne Gasango · Tax & Financial Advisor Brief this Partner →
  17. Saudi Arabia WONE Global Partner Abdullah Yousef Alhussaini · Founding Partner Brief this Partner →
  18. United Arab Emirates WONE Global Partner Priju Dominic · CEO & Founding Partner Brief this Partner →
  19. United States WONE Global Partner F Miles Adler · Principal Brief this Partner →
  20. Vietnam WONE Global Partner Chau Kim Hien · CEO Brief this Partner →
  21. Zambia WONE Global Partner Gerald Zimba · Director Brief this Partner →
  22. Singapore On request Availability confirmed before any work begins Bring a requirement →

Other markets: WONE Global covers 100 countries. Name yours in the requirement →

Katherin Diaz VelillaBogotá · Colombia

WONE Global Capability Partner · Colombia

Katherin Diaz Velilla

Complete profile

Co-Founder · V&V Associates · Bogotá

International tax attorney and strategic advisor with 12+ years across Colombia's DIAN, Ministry of Finance, Senate, Presidency, and EY. Co-founder of V&V Asociados. Specializes in cross-border tax structuring, transfer…

Send Katherin your requirement →
Mauro Tejada RamonQuito · Ecuador

WONE Global Capability Partner · Ecuador

Mauro Tejada Ramon

Tax & Legal Partner · G&G Auditores Independientes & Lex Fiscal Corp · Quito

Professional with 20 years of experience in Tax Administration, performing functions in the managerial and tax administration fields. Experience related to the fiscal field in the main sectors of the economy: Banking, c…

Send Mauro your requirement →
Ulrike Berner, MBAMunich · Germany

WONE Global Capability Partner · Germany

Ulrike Berner, MBA

Managing Partner · BSP Berner Schaeffler & Partners GmbH · Munich

Ulrike Berner has been Managing Director and shareholder of BSP since 2021, leading the strategic direction, client relationships, and business development of the firm. She has extensive experience working with firms an…

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Discover

Where this case connects

The markets, corridors and guides behind this case, and the questions to put to Ask WONE below. Every link opens a page that links back here.

Worked examples

How it goes in practice

Researched corridor journeys, and representative scenarios on the same subject. None is a specific client’s matter.

Tax assessments, disputes & management

Related cases

All 16 cases on this subject →
Urgent We've received a tax notice from another country. Do we have to pay?Urgent We sell online to customers abroad. Do we have to register for their VAT or GST?What tax filings do we have to make in each country, and when?A tax authority abroad is auditing us. How do we respond?The tax authority has challenged our deductible expensesAn overdue tax filing has triggered penaltiesAn asset sale has created an unexpected tax billA business owner faces a personal income tax reassessmentWe want to settle a long-running tax disputeAn employee stock option plan has unexpected tax effects

WONE Global Intelligence

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