Tax & Legal

Categories: All (2 found)

1. 10.12.2025

   ECJ: Documentation requirements for tax exemption and tax re ...

   In a most recent decision on the procedural approach to obtain a WHT exemption, the European Court of Justice (ECJ) has reaffirmed that procedural aspects and formalities can amount to disguised restrictions, and that the practical realization of fundamental freedoms must be ensured. This requires considering not only the relevant provisions of tax law but also any procedural requirements and formalities that may hinder the application of tax benefits or relief.

   Categories: European Court of Justice

   Keywords: refund procedure, dividend withholding t ...
2. 15.03.2017

   Subject-to-tax requirement of the Parent-Subsidiary Directiv ...

   The subject-to-tax provision of the Parent-Subsidiary Directive, whereby distributed dividends are exempt from withholding tax, requires that the dividends are taxed in the hands of the parent company. In practice, this necessitates actual payment of the tax.

   Categories: From Europe

   Keywords: Parent/Subsidiary Directive, subject-to- ...