On 25 January 2007, the hearing in Amurta SGPS v. Inspecteur van de Belastingdienst Amsterdam (case C-379/05) took place before the European Court of Justice (ECJ).
The case concerns the Netherlands withholding tax regime applying in a context where the Parent-Subsidiary Directive (Directive) is not applicable, as the non-resident shareholder's shareholding does not reach the minimum participation required by the Directive. In particular, the issue of the cas…