Spanish National Court

denies exemption from withholding tax to dividends distributed by Spanish subsidiary to US parent company via Netherlands interposed holding companies

The Spanish National Court, in its decision of 22 January 2009 (case number 59/2005), confirmed the decision gave by the Spanish Administrative Tribunal on 15 October 2004 in the case relating to dividends distributed by a Spanish subsidiary to its US parent company via Netherlands interposed holding companies.

Th…