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04 November 2026
The Neo judgement: the anti-abuse provision beyond the direct parent companyIn the NEO judgment of 15 October 2026 (C-203/25), the Court of Justice (hereinafter: the CJEU) further clarified the scope of the anti-abuse provision under the Parent-Subsidiary Directive. This judgment is relevant for the application of the withholding tax exemption in dividend tax and the non-resident corporate income tax.
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