Dutch Supreme Court: AG opines on refund of excessive dividend withholding tax withheld on dividends paid to Belgian resident
On 25 April 2013, Advocate General (AG) Wattel of the Dutch Supreme Court (Hoge Raad der Nederlanden) gave his opinion in Case 12/04717 (recently published) on the refund of excessive dividend withholding tax withheld on dividends paid to a Belgian resident. Details of the opinion are summarized below.
(a) Facts. The Taxpayer (X) is a Belgian resident, who in 2007 derived dividends from the …
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