The Court of Justice of the European Union (CJEU) has rendered its judgment in the AllianzGI-Fonds AEVN case (C‑545/19) finding that Portuguese withholding tax on dividends paid to non-resident investment funds is in breach of EU Law.
This judgment is of great impact to non-resident UCITS and other similar non-resident investment vehicles. Those entities may in fact claim withholding tax incurred in Portugal in the last four years, as well as any withholding tax being applied until the Portuguese legislation is amended to reflect the conclusions of the CJEU’s Judgement.
Read more in our PwC EUDTG news alert.