In the Official Gazette of 21 July 2009, the State Secretary for Finance published Decree No. CPP2009/1310M (the Decree), in response to the decision of the European Court of Justice (ECJ) in Commission v. the Netherlands (C-521/07). In that case, the ECJ held that by not exempting from withholding tax dividends paid to companies established in Iceland and Norway, under the same conditions which apply to dividends paid to companies resident in the Netherlands and other Member States, the Netherlands has failed to fulfil its obligations under Art. 40 of the EEA Agreement. Under the Decree, with effect from 11...