Reference : Opinion Statement ECJ-TF 1/2016 on the Decision of the European Court of Justice in J...
Scientific journals : Article
Analysis of case law/Statutory reports
Law, criminology & political science : Tax law
Opinion Statement ECJ-TF 1/2016 on the Decision of the European Court of Justice in Joined Cases Miljoen (Case C-10/14), X (Case C-14/14) and Société Générale (Case C-17/14) on the Netherlands Dividend Withholding Tax
CFE ECJ Task Force [> >]
Richelle, Isabelle mailto [Université de Liège > HEC Liège : UER > Droit fiscal >]
European Taxation
International Bureau of Fiscal Documentation
Yes (verified by ORBi)
The Netherlands
[en] miljoen ; Société Générale ; C-10/14 ; C-14/14 ; C-17/14 ; Netherlands Dividend
[en] This is an Opinion Statement prepared by the CFE ECJ Task Force on Miljoen and others (Joined Cases C-10/14, C-14/14 and C-17/14),1 in respect of which the Third Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 17 September 2015, following the Opinion of Advocate General Jääskinen of 25 June 2015.2 The cases concern the taxation of dividends received by individual and corporate non-resident taxpayers. They answer several questions in respect of the appropriateness of levying dividend withholding taxes, such as the need to allow for an offset against ordinary income tax, the deductibility of related costs and the relevance of an offset granted by a tax treaty. After illustrating the factual background, parties’ arguments and the ECJ’ s decision, this Opinion Statement will focus on issues that the ECJ has left open.
ECJ Task Force of the CFE ; Tax Institute de l'Université de Liège
CFE (Confédération fiscale européenne)
Professionals ; Students

File(s) associated to this reference

Fulltext file(s):

Restricted access
et_2016_06_cfe_1.pdfPublisher postprint278.98 kBRequest copy

Bookmark and Share SFX Query

All documents in ORBi are protected by a user license.