On 2 April 2020, the Court of Justice of the European Union (CJEU) issued its decision in the GVC Services case (C-458/18) relating to whether or not Bulgaria could deny to a Gibraltar parent company the exemption from withholding tax available under the EU Parent-Subsidiary Directive (PSD) with respect to dividends paid by a subsidiary resident in a Member State to its parent company in another Member State.
The exemption from withholding tax under the PSD is made subject to a number of con…