On 25 January 2007, the hearing in Amurta SGPS v. Inspecteur van de Belastingdienst Amsterdam (case C-379/05) took place before the European Court of Justice (ECJ). The case concerns the Netherlands withholding tax regime applying in a context where the Parent-Subsidiary Directive (Directive) is not applicable, as the non-resident shareholder's shareholding does not reach the minimum participation required by the Directive. In particular, the issue of the case is whether the Netherlands dividend withholding tax regime, which provides for an exemption only for domestic dividends (i.e. those paid to shareholders subject to Netherlands corporate income tax or with a permanent...