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Administrative circular letter confirms Belgian Participation Exemption on EEA-dividends will be applied in line with Cobelfret case |
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In the Cobelfret v. Belgium (C-138/07) case the European Court of Justice (“ECJ”) ruled that the Belgian participation exemption is incompatible with article 4 (1) of the Parent-Subsidiary Directive. For prior coverage on this decision, please see Tax Alert dated 20 May 2009. With the recent publication of the circular letter dated 23 June 2009(Ci.RH.421/597.150), the Belgian Tax Authorities have officially accepted the principles laid down in the Cobelfret case. |
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30-06-2009 |
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