Skip to main content

Event occurred on: 6-10-2021

Profit repatriation from Europe to the US and withholding taxes: How European countries have reacted to ECJ landmark decisions T/Y Denmark and N Luxembourg

When repatriating profits from investments in Europe, (US) investors – multinationals as well as financial investors – seek to rely on treaty relief or exemption under  the EU Directive from European withholding taxes on outbound dividends. 

Such relief is often subject to anti-treaty-shopping and/or limitation of benefits rules. In 2019, in two landmark decisions, the ECJ refined its abuse of law concept as regards withholding tax relief on outbound dividends. Hosted by US GT partner Pam Marcogliese, tax partners Jill Gatehouse (London), Cyril Valentin (Paris), Philipp Redeker (Düsseldorf), Renato Paternollo (Milan) and Bosco Montejo (Madrid) explore how this case law has influenced the application or even the statutory provisions of their countries’ respective anti-abuse provisions and which pitfalls US investors – multinationals and financial investors – need to look out for.

This will take place 9:00am PT/12:00pm EST.

Speakers

Pamela Marcogliese

Partner

See profile >

Jill Gatehouse

Partner

See profile >

Cyril Valentin

Partner

See profile >

Dr. Philipp Redeker

Partner

See profile >

Renato Paternollo

Partner

See profile >

Bosco Montejo

Partner

See profile >
Previous
Next