Judgment of the Court of Justice in the case Wereldhave Belgium.

Council Directive 90/435/EEC on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States must be construed to the effect that Article 5(1) does not preclude legislation of a Member State whereby an advance tax on investment income is levied on dividends paid by a subsidiary established in that Member State to a fiscal investment institution established in another Member State which is subject to corporation tax at a zero rate, provided that all of its profits are paid to its shareholders, since such an institution does not constitute a ‘company of a Member State' for the purposes of that directive.



Informatiesoort: Nieuws

Rubriek: Europees belastingrecht, Vennootschapsbelasting

H&I: Previews


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