Preliminary Ruling Requested from ECJ on Dividend Withholding Tax Due by UK Insurance Companies

Abstract

In this note, the author comments on the recent request from the Court of Appeal of ‘s-Hertogenbosch for a preliminary ruling from the ECJ on the imposition of a 15% dividend withholding tax on dividend distributions to UK insurance companies on unit-linked policies in circumstances in which no withholding tax was due on payments to domestic pension funds.