Luxembourg has published Circular L.I.R. no. 147/2, 166/2 et Eval. no. 63 of 1 December 2020, concerning the application of the EU Parent-Subsidiary Directive (PSD) with respect to dividends paid to Gibraltar.
The Circular references the 2 April 2020 decision of the Court of Justice of the European Union (CJEU) in the GVC Services case (C-458/18), which found that Bulgaria is permitted to exclude Gibraltar parent companies from the application of the dividend withholding tax exemption other…