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
What the paper says
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.
Evidence weight
Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40
| F · citation impact | 0.50 × 0.4 = 0.20 |
| M · momentum | 0.50 × 0.15 = 0.07 |
| V · venue signal | 0.50 × 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.