Germany: Inter-corporate dividend withholding tax hinders free movement of capital

December 15 2011

In a case brought by the European Commission (EC) (C-284/09 Commission v Germany, judgment of October 20 2011), the European Court of Justice (ECJ) held that Germany’s withholding tax on dividends to other corporations is in breach of community law in that it discourages persons from abroad from investing in Germany.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

Money exchange abroad with business data ai technology. Concept for digital money transfer banking and world economic financial investment trading. 3D illustration banner.

Transfer pricing automation in ERP systems: traps for compliance

Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies

Arin Mitra, June 11 2026

Direct Tax

KPMG gears up for hearing amid confidential leaks scandal

The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign

Sam Sholli, June 10 2026

Direct Tax

r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.

Capital v revenue in R&D – isolated concerns or a future battleground? Part one

In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully

Jayne Stokes, June 09 2026

Direct Tax

A&M Tax continues Europe push with Sweden launch

Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax

Sam Sholli, June 08 2026

Direct Tax

Pillar two criticism fair despite filing penalty waiver: BDO tax leader

The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals

Sam Sholli, June 08 2026

Direct Tax

A taxing week: Ryan’s Svalner Atlas deal shows that size does matter

The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game

Tom Baker, June 05 2026

Direct Tax

This week in tax: Taxand expands UK network with Unity Advisory

The big four spin-off firm becomes Taxand’s second UK member; in other news, Haynes Boone launched a UK tax practice

Tom Baker, June 05 2026

Transfer Pricing

‘TP is a team sport’: NRF’s new hire on practice-building

Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says

Sam Sholli, June 04 2026

Direct Tax

International law firm launches with tax as key focus

Mada has opened simultaneously in Paris and Dubai with an eight-lawyer team from Trinity International

Tom Baker, June 03 2026

Indirect Tax

This month in indirect tax: Fonoa acquires PwC indirect tax tech platform

PwC will continue to provide indirect tax services as part of the deal; in other news, the CJEU addressed the VAT treatment of TP adjustments

Tom Baker, June 03 2026