Recently, the Belgian administration published Circular Ci. RH.233.609.958 (No. AA Fisc No. 26/2013) on the granting of a refund of dividend withholding tax following the decision of the European Court of Justice (ECJ) in Tate & Lyle Investments (Case C-384/11).

In the case, the ECJ, inter alia, decided that the free movement of capital must be interpreted as precluding legislation, wh…

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