Belgian Court rules on abuse of Parent-Subsidiary Directive after the Danish cases
On 1 December 2020, the Ghent Court of Appeal ruled on the question whether the exemption of withholding tax (WHT) laid down in the Parent-Subsidiary Directive (PSD) could be refused on the basis of abuse. This case is particularly relevant because it is the first time that a Court of Appeal has applied the Danish cases. The implications cannot be underestimated, especially in an M&A environment.
Natalie ReypensPartner Attorney at Law
Natalie Reypens is a member of the Loyens & Loeff International Tax Services Practice Group and heads the Belgian Transfer Pricing Team. She is a partner in our Brussels office. She focuses on corporate and international tax law.T: +32 2 743 43 37 E: email@example.com
Benno DaemenAssociate Attorney at law
Benno Daemen, attorney at law, is a member of the Loyens & Loeff International Tax Services Practice Group in Belgium. He is an associate in our office in Brussels and specialises in corporate income tax and international tax law.T: +32 2 773 23 67 E: firstname.lastname@example.org
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