In the Official Gazette of 21 July 2009, the State Secretary for Finance published Decree No. CPP2009/1310M (the Decree), in response to the decision of the European Court of Justice (ECJ) in Commission v. the Netherlands (C-521/07). In that case, the ECJ held that by not exempting from withholding tax dividends paid to companies established in Iceland and Norway, under the same cond…