Advisius The NEO Case: Dividend chains under scrutiny Substance is not a safe harbor. The entire chain is relevant. No presumptions: the burden of proof lies with the tax authorities. The knowledge of the distributing company is irrelevant. Abuse Belgium DBI DRD GAAR RDT holding parent-subsidiary tax
Advisius Dividends Abuse - Double non-taxation and the EU General Anti-Abuse Rule On June 6, 2025, the Leuven Court of First Instance handed down a judgment resolving a dispute over the exemption in Belgium of dividends received by a Belgian company belonging to an international group (the Johnson Controls group). DBI DRD GAAR RDT corporate tax dividend holding parent-subsidiary
