On 28 September 2012, the Netherlands Supreme Court (Hoge Raad der Nederlanden) gave its decision in case No. 11/00672, X. v. Staatssecretaris van Financiën. The case concerned the refund of dividend withholding tax and interest compensation (heffingsrente) regarding a dividend payment by a Dutch subsidiary to a Spanish parent company. Details of the decision are summarized below. (a) Facts. X (the Taxpayer) is a Spanish resident company, subject to corporate income tax in Spain. All the shares in the Taxpayer are held by the Spanish state. The Taxpayer has a 5.48% shareholding in A. N.V. (A.), a Dutch public company. Over...