On 28 November 2012, Advocate General (AG) Wattel gave his opinion in case No. 12/01866 (recently published) on the refund of dividend withholding tax to a collective investment vehicle (CIV) resident in Finland.

The AG started his opinion by summarizing article 10(1) of the Dutch Dividend Withholding Tax Law (DWTL). This article essentially provides for a refund of dividend withholding tax…