On 11 May 2007, the Dutch Supreme Court ruled on a triangular case (No. 42.385) involving the availability of a credit for withholding tax on interest receipts of a Belgian permanent establishment (PE) of a Dutch company, derived from third state sources. (a) Facts. A Dutch BV carried out business activities in Belgium through a PE. The Dutch BV had debt claims on Brazilian and Italian group companies, the indebtedness of which was borne by the Belgium PE. In 1996, the Dutch BV received interest income on these debt claims, which were attributable to the Belgium PE under the 1970...