OrbitaxNetherlands Supreme Court holds that dividend withholding tax on distributions to Luxembourg minority shareholder incompatible with free movement of capital
|Approved Changes|Netherlands
On 30 November 2007, the Dutch Supreme Court decided a case (No. 42679) on the compatibility of the imposition of withholding tax on dividend distributions by a Netherlands limited liability company (BV) to a Luxembourg minority shareholder (SARL).
(a) Facts. The taxpayer is a Luxembourg company (SARL), which owned a 2.25% shareholding in a Netherlands company (BV) that in turn headed…
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