EYSpanish National High Court overturns denial of withholding tax exemption on dividend payments to EU shareholder
|Tax Alerts, Legislation & Policy, Na ...|Luxembourg, Spain, European Union
Executive summary
The Spanish National High Court issued a Decision on 25 May 2021 (the Decision), recently published, upholding the withholding exemption for dividend payments (DWHT) by a Spanish company to a Luxembourg company. This decision overturns the criteria of the Spanish tax authorities, which had rejected the withholding exemption on the basis that the latter is not incorporated for vali…