According to recent reports, the Spanish National High Court issued an important decision on 25 May 2021 concerning the application of the withholding tax exemption on dividends under the EU Parent-Subsidiary Directive (PSD) and related anti-abuse rules in relation to EU holding structures. The case involved the payment of dividends by a Spanish company in 2009 and 2010 to a Luxembourg company wholly owned by a Canadian pension fund, for which the PSD exemption was claimed. The Spanish tax au…