Advocate General Opinion Issued on Belgian Withholding Tax on Dividends Paid to Dutch Parent Subject to Zero Rate of Tax

On 26 October 2016, the opinion of Advocate General Campos Sánchez-Bordona of the Court of Justice of the European Union (CJEU) was published concerning tax withheld at source on dividends paid by a Belgian subsidiary to its Dutch parent. The case involves Wereldhave Belgium, a limited partnership with a share capital, which is jointly owned by Dutch parents Wereldhave International (35%) and Wereldhave (45%). The Dutch parents are collective investment undertakings incorporated as public lim…