The Finnish Central Tax Board (Keskusverolautakunta, or KVL) issued an advance ruling on 25 January 2006 (KVL 2/2006) in a case regarding Finland's right to impose, under EC law, withholding taxes on Finnish-source dividends received by a Luxemburg SICAV from its 100% owned subsidiary in Finland. The main features of the ruling are summarized below:
(a) Decision. The KVL first stated in its decision that, as a SICAV is not referred to in the Appendix to the EC Parent-Subsidiary Di…