PwC initiative secures millions of pounds of tax refunds for UK pension schemes

Published at 10:09 AM on 11 February 2009

  • PricewaterhouseCoopers (PwC) first to file claims for pension scheme clients to secure Dutch withholding tax refunds
  • PwC first to market with initiatives to eliminate discriminatory withholding taxes on cross border dividends to pension schemes within the EU having filed a joint complaint with the European Commission in 2005 against 18 out of 25 EU member states, together with the European Federation for Retirement Provision (EFRP)
  • The refunds mark a positive development in a series of protracted discussions with other European countries

UK pension schemes represented by PwC will receive tax refunds in excess of €35m (£30m) from the Dutch Tax Authorities after those investing in the Netherlands suffered withholding taxes on Dutch dividends that Dutch schemes were not required to pay. PwC was the first firm to file protective withholding tax claims for clients under the EC Treaty principle of free movement of capital between member states. They have filed claims for Pension Funds and other investment vehicles for in excess of €500m across Europe.

PwC have already been successful in securing refunds for UCITS funds (Undertakings for Collective Investment in Transferable Securities) and non-UK pension scheme clients in Europe. A number of territories have already changed their laws after the EC launched infringement proceedings following the complaint filed by PwC’s EU direct tax group and the EFRP in December 2005.

Despite these developments, the Dutch Tax Authorities have not officially conceded their tax withholding laws were in breach of EC Treaty principles and a number of other countries have yet to deal with EC pressure to provide refunds or change their laws. 

Robert Mellor, PwC UK financial services tax leader, commented:

"The freedom of movement of capital should drive equality of tax treatment for investors across the European Union and these developments are further welcome steps on the road to achieving that. I expect more and more countries to follow suit over time.” 


For more information contact:

Lydia Ruffles
Financial Services, PR Manager, PwC 
Tel:+44 (0)20 7212 1798 
Mobile:07966 319 780 

Robert Mellor
UK Financial Services Tax Leader, PwC 
Tel:020 7804 1385 


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