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Peter Cussons International Corporate Tax Partner PricewaterhouseCoopers LLP discusses the recent Denkavit withholding tax case judgment
On 14 December 2006 the European Court of Justice (ECJ) delivered its judgment in favour of the taxpayer in the Denkavit withholding tax case — Denkavit Internationaal BV/Denkavit French Sarl v the French Ministry for Economy Finance and Industry C-170/05.
The Facts
Denkavit Internationaal BV owned 50% of the share capital of Denkavit France Sarl and 99.9% of the capital of another French company Agro Finance which itself owned the other 50% of Denkavit France Sarl.
In 1987 to 1989 (so before the EC Parent/Subsidiary Directive...

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