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Belgium tightens dividend WHT exemption for non-residents – ECJ widens it

16 January 2013

As from 7 January 2013, the Belgian dividend withholding tax exemption previously available to non-residents which are non-profit entities exempt from income tax in their state of residence, will be available only to non-resident pension funds. On the other hand, foreign investment funds and corporate portfolio investors can consider relying on recent ECJ case law to claim an exemption (for future dividends) or a refund (for past dividends). These recent developments may impact on Belgian equities transactions around dividend date.

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