OrbitaxNetherlands dividend withholding tax on distributions to Luxembourg minority shareholder incompatible with EU law
|Treaty Development|Netherlands-Luxembourg
On 9 September 2005, the Court of Appeal at 's-Hertogenbosch decided a case on the compatibility of the imposition of withholding tax on dividend distributions by a Netherlands limited liability company (BV) to a Luxembourg minority shareholder (SARL).
(a) Facts. The taxpayer is a Luxembourg company (SARL), which owned a 2.25% shareholding in a Netherlands company (BV) that i…
Continue Reading
