EYSpanish Central Tax Court applies doctrine of ECJ Danish cases to deny withholding tax exemption on dividend payments to EU shareholders
|Tax Alerts, Legislation & Policy, Na ...|Spain, European Union
Executive summary
The Spanish Central Tax Court issued a Decision on 8 October 2019 (the Decision), recently published, confirming the rejection of the withholding tax exemption for dividend payments by a Spanish company to a Luxembourg company on the basis that the latter is not the beneficial owner of such payments.
The Decision follows the beneficial ownership stance expressed by the European Cou…
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