How Protocol works

Straight through processing

From raw data collection and validation, to identification of (additional) recovery entitlements, all the way through to processing and filing complete claims. And with that, protocol minimizes the time, effort and expense involved in withholding recovery, while increasing withholding tax recovery significantly.

How it works

The efficiency of protocol immediately translates into improved investment performance.

STEPS

An intuitive process

Depending on whether investments are pooled Protocol follows an intuitive 3 or 4 step process

Upload pool participations
If investments are pooled, pool participation data (excel / csv) is uploaded into Protocol in order to determine each pool participant’s pro rata share in dividends received by the pools.

Not all pool participation data is formatted equally. Therefore Protocol will match the headers from the pool participation data with its own template. If the headers don’t match, you can manually assign them to your pool participation data sheet. Protocol learns and stores any manual changes for a next pool participation import to speed up the import process.

Protocol rewrites and verifies the pool participation data to create a file that is tax compliant and compatible with all dividend data. Protocol’s data analysis filters out mathematical errors, such as negative pool ownerships, pool ownerships that add up to more, or less, than 100% on any given date.

Upload income data
Income data (excel / csv) is uploaded into Protocol, sorted by claim country and claim year.

As not all income data sheets are formatted equally, Protocol will match the headers from the income data sheet with its own template. If the headers don’t match, you can manually assign them to your data sheet. Protocol learns and stores any manual changes for a next income data import to speed up the import process.

Protocol’s data analysis filters out errors, for example if share quantity x gross dividend per share does not equal gross dividend amount.

Protocol automatically converts foreign currency income to the source country’s currency prevailing on the pay date, and verifies whether each income receipt is correctly backed by a proof of payment (e.g. a dividend voucher).

If investments are pooled, Protocol applies the income data against the pool participations and calculates the unclaimed WHT for each pool participant.

Claim Analysis
After every income data import, Protocol will determine the highest possible WHT recovery claim in the relevant claim country. In doing so, it will analyze various possible legal bases for a refund of WHT, such as the applicable bilateral tax treaty, the EU treaty, domestic law, etc.

Simultaneously, Protocol will compare the unrecovered WHT in the income data sheets against its analysis of the highest possible WHT recovery claim, based on its state-of-the-art global withholding tax tax data base. In this step, Protocol checks what WHT reduction or recovery has already been applied (e.g. by the custodian).

Every successful import of income data, will show in Protocol’s tax analysis overview. This overview shows, per year and per country, how much WHT can be reclaimed based on Protocol’s analysis of the imported data.

Where Protocol concludes that a (further) refund of unrecovered WHT can be obtained, it will propose to file a WHT refund claim, and – in the case of pooled investments – provide an exact breakdown of the claim amount per participant.

The overview also shows withholding tax already claimed, and claim filing deadlines. Email notifications of upcoming claim deadlines are sent automically to designated users, at adjustable intervals.

Complete and submit claim
When a WHT recovery claim is selected from the tax analysis overview, Protocol will guide you through the process of completing the claim to meet the claim country’s procedural requirements and submitting the claim.

Automated filing

Protocol knows the applicable refund procedure and documentation requirements of each claim country. In claim countries which support electronic filing of refund claims the claim will be filed electronically after clicking on the submit claim button, and the claim and supporting documentation will automatically be stored in the WHT position overview. Protocol is updated for any electronic response from the tax administration.

Manual filing

In claim countries which do not (yet) support electronic filing , Protocol will generate the requisite claim information and documentation. This includes a standardized refund request letter, containing all relevant data and descriptions regarding the claimants, and addressed to the authorized tax office in the claim country. It also includes automatically pre-filled official refund request forms as applicable in the claim country) and may ask to upload certain documents like certificates of residence.

Next, the complete claim can be printed and filed by clicking on the submit claim button. The claim and supporting documentation will automatically be stored in the WHT position overview.