Distributions from Luxembourg investment company (SICAV) exe ...
Corporations with at least a 25% share in a Société d'investissement à capital variable (SICAV), a Luxembourg investment company, do not have to pay income tax in Germany on the dividends received from the SICAV in 2010. This also applies if the Luxembourg tax authorities – for whatever reason - did not exercise their right of taxation at source and the distributions hence remained untaxed.
Categories: Supreme Tax Court cases
Keywords: SICAV, intercompany dividend privilege