OrbitaxECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
|Approved Changes|European Union/Austria/Switzerland
On 24 May 2007, the European Court of Justice (ECJ) gave its decision in the case of Winfried L. Holböck v. Finanzamt Salzburg-Land (C-157/05). Details of the judgment are summarized below.
Issue. The issue in the case was whether or not the different taxation of dividends received by Austrian resident shareholders holding two-thirds of the capital of a company resi…
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