Jochem van der Wal Tax Lawyer Loyens & Loeff on the EFTA Court decision in Fokus Bank: a devastating decision for European withholding tax systems?
In November 2004 the Court of the European Free Trade Association (EFTA Court) decided a case brought by the Norwegian company Fokus Bank ASA.1 Fokus Bank claimed that Norwegian dividend tax legislation — like the withholding systems applied by many other jurisdictions — treated domestic shareholders more favourably than foreign non-Norwegian shareholders. The EFTA Court essentially decided that a national dividend tax system must treat residents and non-residents entirely the same. The Fokus Bank case is the first European-level court case dealing with the tax treatment of outbound dividends. A similar not yet published case has recently been referred to the European Court of...
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Jochem van der Wal Tax Lawyer Loyens & Loeff on the EFTA Court decision in Fokus Bank: a devastating decision for European withholding tax systems?
In November 2004 the Court of the European Free Trade Association (EFTA Court) decided a case brought by the Norwegian company Fokus Bank ASA.1 Fokus Bank claimed that Norwegian dividend tax legislation — like the withholding systems applied by many other jurisdictions — treated domestic shareholders more favourably than foreign non-Norwegian shareholders. The EFTA Court essentially decided that a national dividend tax system must treat residents and non-residents entirely the same. The Fokus Bank case is the first European-level court case dealing with the tax treatment of outbound dividends. A similar not yet published case has recently been referred to the European Court of...
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