New Dutch dividend stripping measures introduced
New Dutch dividend stripping measures introduced 20 SEPTEMBER, 2023 | TAX NEWS On September 19, the Dutch government presented its 2024 Budget Plan. The plan introduces new measures against dividend stripping. Dividend stripping There are two categories of transactions that are considered to be dividend stripping: so called cum ex and cum cum transactions. I
European Commission issues proposal for EU withholding tax system
European Commission issues proposal for EU withholding tax system 21 June, 2023 | TAX NEWS On 19 June 23, the European Commission released its proposal for an EU Directive for an EU wide withholding tax system. The proposal is structured in two building blocks which are covered in chapters 2 and 3, respectively. Chapter 2 […]
German Supreme Court dismisses appeal in Canadian pension fund ECJ reclaim
German Supreme Court dismisses appeal in Canadian pension fund ECJ reclaim 16 December, 2022 | TAX NEWS Germany ECJ reclaim dismissed by German Supreme Court On December 1st, 2022 the Supreme Court of Germany (Bundesfinanzhof) dismissed the ECJ reclaim submitted by College Pension Plan, a Canadian pension fund. In its decision, the Supreme Court rejected [
Dutch Court of Appeals refers ECJ reclaim case to European Court of Justice
Dutch Court of Appeals refers ECJ reclaim case to European Court of Justice 14 December, 2022 | TAX NEWS Dutch Court of Appeals refers ECJ reclaim case to European Court of Justice. On December 14th, a Dutch court of appeals issued a decision in which it referred the case to the European Court of Justice […]
Denmark proposes dividend withholding tax for foreign government investors
Denmark proposes dividend withholding tax for foreign government investors 29 September, 2022 | TAX NEWS Denmark proposes a dividend withholding tax for foreign governments (in a multi-facetted tax bill on September 23rd, 2022). Whereas foreign government and foreign government body investors are currently eligible for a full exemption (or refund) of Danis
Dutch tax authorities claw back millions in ECJ reclaims
Dutch tax authorities claw back millions in ECJ reclaims 21 September, 2022 | TAX NEWS Dutch tax authorities to claw back millions in ECJ reclaims. Last week, the Dutch tax authorities have started a large scale re-examination of foreign pension funds’ entitlement to reclaims of Dutch dividend withholding tax based on the free movement of […]
Italian Supreme Court says US pension fund is entitled to same reduced dividend withholding tax rate as Italian pension funds
Italian Supreme Court rules that US pension fund is entitled to same reduced dividend withholding tax rate as Italian pension funds 14 September, 2022 | TAX NEWS Italian Supreme Court rules that US pension fund is entitled to same lower dividend withholding tax rate as Italian pension funds. Case facts In 2008 and 2009, a […]
Taiwan lifts FINI withholding tax statement requirement
Taiwan lifts FINI withholding tax statement requirement 9 September, 2022 | TAX NEWS Taiwan lifts FINI withholding tax statement requirement. The Taiwanese Ministry of Finance issued a statement on September 2nd, 2022 saying that the procedure for a Foreign Institutional Investor (FINI) to provide the withholding tax statement when applying for a refund of
Cum-ex transactions explained
Cum/ex transactions explained 31 August, 2022 | TAX NEWS On August 31st, 2022, the Financial Times reported that JPMorgan’s Frankfurt’s office was raided by German prosecutors as part of a probe into the multibillion dollar cum/ex scandal. After Barclays, Bank of America, and MorganStanley, JPMorgan is the fourth bank to be raided by the Germ
EU wide withholding tax system: European Commission public consultation summary report
European Commission publishes summary report on its public consultation on an EU wide withholding tax system 8 August, 2022 | TAX NEWS On August 4th, 2022, the European Commission published its summary report on the public consultation on its proposed EU wide withholding tax system. The report can be seen by clicking here. The problem […]