On 27 March 2009, the Lower Court of Haarlem gave its decision in the case No. AWB 07/5534 concerning the compatibility of the withholding tax on dividends paid to a Canadian parent company with the free movement of capital (Art. 56 of the EC Treaty). (a) Facts. The taxpayer was a company formed under Dutch law with its effective management in the Netherlands. In 2005, the taxpayer held participations in 12 foreign companies, i.e. a 100% participation in 9 companies and a 50% participation in the remaining 3 companies. F Limited was the sole shareholder of the taxpayer. It had...