On 24 May 2007, the European Court of Justice (ECJ) gave its decision in the case of Winfried L. Holböck v. Finanzamt Salzburg-Land (C-157/05). Details of the judgment are summarized below.
Issue. The issue in the case was whether or not the different taxation of dividends received by Austrian resident shareholders holding two-thirds of the capital of a company resident in a third State (non-EU country), as compared to dividends received by such shareholders fro…