The future of asset servicing : Unlocking operational alpha in an increasingly complex withholding tax landscape

Abstract

This paper examines how withholding tax relief and recovery are being repositioned within asset servicing, from a largely administrative post-trade activity to a component of asset value preservation. As investors place increasing pressure on custodians, asset servicers, and asset managers to reduce tax leakage and optimise net returns, efficient withholding tax processes are becoming an important source of operational alpha. At the same time, the ability to capture that value is becoming increasingly difficult. Administrative complexity, heightened tax authority scrutiny, European Court of Justice (ECJ) case law, regulatory reform, and digitalisation are reshaping the conditions under which withholding tax relief and recovery must be achieved. Technology and artificial intelligence (AI) may improve scale, consistency, and transparency, but sustainable recovery outcomes still depend on legal judgment, robust documentation, governance, and operational oversight. The paper concludes that these developments require institutions to reassess the role of withholding tax recovery within their operating models. In an environment of greater opportunity and greater complexity, withholding tax recovery is becoming an increasingly important capability, whether managed internally, outsourced, co-sourced, or through specialist partnerships. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.