According to the double tax treaty in place between Luxembourg and Finland, the dividends received by LuxCo on shares held in the framework of unit-linked life insurances are subject to 15% WHT levied in Finland. The same situation applies...
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While at the moment foreign funds are subject to WHT in Germany, from 2018 onwards domestic (i.e. German) and foreign investment funds will both be taxed on German dividends. Notwithstanding the current lack of interpretation for what relates the...
Italian Tax Court rules dividend withholding tax on non-EU pension funds is in breach of EU’s free movement of capital principle. Italy’s Provincial Tax Court of Pescara (1st ITC) is in charge of issuing 1st instance decisions on withholding...
On 8 June 2016, the Dutch Government issued a press release stating that two competent authorities agreements (the Agreements) have been signed with Switzerland regarding the application of the Netherlands–Switzerland double tax treaty (the Tax Treaty). The first agreement...
In July 2016, the Finnish Parliament passed a bill amending the statute of limitations applicable to the tax assessment of various taxes. In addition to the amendments to the statute of limitations under the tax assessment procedure, the withholding...
Dutch Supreme Court ruling of 10 July 2015 The Supreme Court ruled on 10 July 2015 that a foreign investment fund cannot obtain a refund of Dutch dividend withholding tax incurred on its dividend income as it is not...
The Danish Minister of Taxation proposal to reduce the deadline for reclaims of Danish dividend withholding tax from 5 to 3 years, will be effective the 13th of September 2016 The deadline will be changed from 5 to 3 years,...
The Commission has requested the Netherlands to end the discriminatory taxation of dividends received on shares held by insurance companies established elsewhere in another Member State or in an EEA country (Norway, Lichtenstein and Iceland). Dutch insurance companies are...
The Finnish Act on Taxation of Nonresident Income (Laki rajoitetusti verovelvollisen tulon verottamisesta) has been amended in respect to withholding taxation of dividends distributed to nonresident pension funds. This amendment brings the withholding tax rules into conformity with EU...
On 10 April 2014, the Court of Justice of the European Union (CJEU) rendered its decision in case C-190/12 Emerging Markets Series of DFA Investment Trust Company. The CJEU found that the exclusion of a non-EU investment fund, specifi- cally...