arbiter
JournalsAccount

The Belgian Dividend Withholding Tax Exemption Cases: Scope for Reasonable Doubt that the Object and Purpose of the Parent-Subsidiary Directive (2011/96) Had Been Defeated?

Maarten De Wilde & T.Mees Vergouwen

European Taxation2026https://doi.org/10.59403/39p5hfcarticle
ABDC B
Weight
0.50

Abstract

On 18 July 2025, the Dutch Supreme Court ruled (implicitly) that granting the Dutch dividend withholding tax exemption for dividends distributed to Belgian tax resident intermediate holding companies of Belgian resident individuals would defeat the object and purpose of the EU Parent-Subsidiary Directive (2011/96). The absence of a request for a preliminary ruling in respect of this judgment implies that there was no scope for reasonable doubt that such object and purpose would have been violated had the withholding tax exemption been granted. This article examines the grounds for this absence of scope for reasonable doubt.

Open via your library →

Cite this paper

https://doi.org/https://doi.org/10.59403/39p5hfc

Or copy a formatted citation

@article{maarten2026,
  title        = {{The Belgian Dividend Withholding Tax Exemption Cases: Scope for Reasonable Doubt that the Object and Purpose of the Parent-Subsidiary Directive (2011/96) Had Been Defeated?}},
  author       = {Maarten De Wilde & T.Mees Vergouwen},
  journal      = {European Taxation},
  year         = {2026},
  doi          = {https://doi.org/https://doi.org/10.59403/39p5hfc},
}

Paste directly into BibTeX, Zotero, or your reference manager.

Flag this paper

The Belgian Dividend Withholding Tax Exemption Cases: Scope for Reasonable Doubt that the Object and Purpose of the Parent-Subsidiary Directive (2011/96) Had Been Defeated?

Flags are reviewed by the Arbiter methodology team within 5 business days.

Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.