A recent decision of Austria's Supreme Administrative Court has been published regarding the refund of withholding tax paid on dividends. The case involved a pension fund wholly owned by the Canadian government that received dividends on shares held in an Austrian stock corporation. Withholding tax was withheld at a rate of 25%, with 10% refunded based on the 15% withholding tax rate provided under the 1976 Austria-Canada tax treaty. The pension fund then requested a full refund based on section 21(1)(1a) of the Austrian Corporate Tax Act, which provides for a full refund for taxpayers in certain cases where the...