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Following on from Stephen Edge's article last week Peter Cussons PricewaterhouseCoopers LLP revisits the ratio in Advocate-General (A-G) Geelhoed's Opinion in Denkavit and considers some wider implications
Denkavit International BV and Denkavit France Sarl v the Ministry for Economy Finance and Industry concerned a Dutch company with two French subsidiaries. Under the Dutch/French double tax treaty 5% withholding tax was levied on dividend payments which a French company in the same situation would not have incurred.
Economic double taxation
The A-G's Opinion of 27 April 2006 focuses on the economic double taxation of the profits of the relevant French subsidiary: Denkavit France Sarl. Firstly those profits are subject...
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