Dutch Supreme Court decides that Netherlands not obliged to grant credit for Brazilian and Italian withholding tax on interest derived by Belgian PE of Dutch company
On 11 May 2007, the Dutch Supreme Court ruled on a triangular case (No. 42.385) involving the availability of a credit for withholding tax on interest receipts of a Belgian permanent establishment (PE) of a Dutch company, derived from third state sources.
(a) Facts. A Dutch BV carried out business activities in Belgium through a PE. The Du…
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