On 26 October 2016, the opinion of Advocate General Campos Sánchez-Bordona of the Court of Justice of the European Union (CJEU) was published concerning tax withheld at source on dividends paid by a Belgian subsidiary to its Dutch parent. The case involves Wereldhave Belgium, a limited partnership with a share capital, which is jointly owned by Dutch parents Wereldhave International (35%) and Wereldhave (45%). The Dutch parents are collective investment undertakings incorporated as public limited companies that are liable to corporation tax, but are subject to a zero rate. In 1999 and 2000 Wereldhave Belgium distributed profits to its Dutch...