In 1994, the Dutch Supreme Court ruled that a UK person legally entitled to receive dividends from a Dutch company could claim reduced Dutch dividend withholding tax of 15% under the UK/Netherlands tax treaty. The case in question involved a Luxembourg company that sold Shell dividend coupons to a UK market maker at 80% of their nominal value. Since the Luxembourg company was not entitled to the benefits of a tax treaty, it would otherwise have suffered 25% dividend withholding tax on dividends it received from Shell in the Netherlands.
June 30 1999