In two recent decisions, the Belgian Court of Appeal of Ghent ruled on the tax treatment of a dividend distribution by a Belgian company to its Luxembourg holding vehicle. In both cases, the tax exemptions applied at source were denied on the basis of general anti-abuse principles.The cases are landmark cases as they provide a first insight on how the general anti-abuse provision (GAAR) may be applied to a series of transactions considering the findings of the Court of Justice of the European Union (CJEU) Danish Cases (see EY Global Tax Alert, CJEU rules on application of Danish withholding tax...