On 15 November 2013, the Netherlands Supreme Court (Hoge Raad der Nederlanden) gave its decision in case No. 12/01866 on the refund of dividend withholding tax to a collective investment vehicle (CIV) resident in Finland.
For the Advocate General's opinion, as well as the facts, legal background and issues.
The Court began by stating that in order to ascertain whether or not the Finnish CIV (the Taxpayer) was entitled to a refund of dividend withholding tax under article 63 of t…