As part of the ULME research semester, Moritz Scherleitner (Aalto University, Helsinki) will give a talk on the topic “Addressing Dividend Stripping Arrangements: A Discussion of Different Policy Options”.

Date: 28 May 2026

Time: 4.15 pm

Where: Helmholtzstrasse18, Room 1.20

Mr Scherleitner will be present this afternoon before and after the lecture. It is possible to join him for lunch or dinner. If you are interested, please contact Ms Sandra Ludwig (sandra.ludwig(at)uni-ulm.de)

Abstract:

Jurisdictions seeking to safeguard their dividend withholding tax base against traditional treaty-shopping
structures involving conduit companies should be equally concerned about dividend-stripping arrangements that eliminate source-state WHT through the use of derivatives. Nevertheless, a recent OECD study (2023) indicates that awareness of such practices remains limited. This paper aims to provide tax policymakers with guidance on how dividend stripping may be addressed, taking into account that jurisdictions differ both in their perceived urgency regarding the problem and in the administrative capacity they can devote to it. To this end, we first examine the extent to which existing anti-abuse rules (including GAAR-type provisions) are capable of countering dividend-stripping transactions. We then turn to targeted anti-abuse approaches and present our own proposal, the Equity Ownership Quotient.