On 18 July 2025, the Dutch Supreme Court issued two related judgments concerning the application of Dutch dividend tax anti-abuse rule (Article 4(3)(c) of the Dividend Tax Act) to Belgian holding companies receiving dividends from Dutch entities. The holding companies were ultimately owned by different Belgian families (natural persons). Both cases involved challenges of 5% dividend tax withholding, with the owners arguing that their structures were not artificial and an exemption should appl…