๐–๐“๐’ ๐†๐ฅ๐จ๐›๐š๐ฅ ๐…๐ข๐ง๐š๐ง๐œ๐ข๐š๐ฅ ๐’๐ž๐ซ๐ฏ๐ข๐œ๐ž๐ฌ ๐๐ž๐ฐ๐ฌ๐ฅ๐ž๐ญ๐ญ๐ž๐ซ

We hope you may find interesting the September 2025 version of the WTS Global Financial Services Newsletter, presenting the following taxation-related news from 12 countries, alongside with one additional hot topic, with a focus on the international Financial Services industry, covering a diverse range of international Financial Services tax topics:

  • Hot Topic: Germany – Regulated investment funds: New draft bill increases certainty
  • Austria: ECJ largely confirms Austrian legislation denying WHT refund to foreign CIVs
  • China: VAT resumed on bonds interest income – QFII exemption uncertain after 2025
  • India: IFSC in focus – Tax exemption for non-residents on derivative profits in IFSC
  • Indonesia: The tax treatment of crypto assets in Indonesia
  • Luxembourg: Proposal regarding major enhancements to carried interest regime; New Circular clarifies the definition of a โ€œcollective investment vehicleโ€ for the purpose of its carve-out from the reverse hybrid rules
  • Poland: Finance Minister’s guidance of 3 July 2025 regarding the use of beneficial owner test for WHT purposes; Proposed changes to CIT Act regarding corporation tax exemptions for foreign investment funds; Recent judgments of Poland’s top tax court on exemption for foreign investment funds; Draft regulations to disapply the pay and refund mechanism for technical payers until 31 December 2026; Finance Ministry – Ideas to fund the budget deficit at the expense of the banking sector
  • Republic of Korea: Foreign investors and multinational enterprises – Impact of key 2025 Korean tax reform proposals
  • Singapore: Substance at the top- IRAS pragmatic take on SPVs and investment funds
  • Spain: CJEU to rule on WHT discrimination of investment funds resident in the U.S. investing in Spain
  • Taiwan: Update – Financial Services news 2025 for Foreign Institutional Investors
  • The Netherlands: Dutch Supreme Court – Two landmark rulings – Applicability of the dividend WHT exemption in cross-border investment structures; European Commission challenges Dutch dividend tax reduction scheme – implications for investment funds

๐€๐œ๐œ๐ž๐ฌ๐ฌ ๐ญ๐ก๐ž ๐Ÿ๐ฎ๐ฅ๐ฅ ๐ง๐ž๐ฐ๐ฌ๐ฅ๐ž๐ญ๐ญ๐ž๐ซ – WTS Global Financial Services Newsletter #36