Recently, a Decree of 20 December was published that restricts the exemption from dividend withholding tax for non-resident non-profit entities, which are exempt from tax in their residence state to pension funds. Details of the Decree, which applies from 1 January 2013, are summarized below.
Before 2013, next to pension funds also other non-resident non-profit and exempt entities, such as charities, could claim an exemption from dividend withholding tax.
From 2013, the exemption can onl…