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Spanish National High Court issues favorable decisions with respect to international holding structures after ECJ Danish cases

|Tax Alerts, Legislation & Policy, Na ...|Spain, European Union
Spain, European Union

Executive summary

The Spanish National High Court recently issued three decisions regarding the application of the dividend withholding tax (DWHT) exemption under the European Union (EU) Parent Subsidiary Directive (EU PSD) and the beneficial ownership requirement related to an EU holding structure.

These decisions, which are favorable to the taxpayer, differ from the more general position taken by …

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