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EU Law Based Withholding Tax Claims

Private equity funds – a focus on risk management

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Over recent years there has been a significant amount of activity in the European Union (EU) regarding the compatibility of EU Member State dividend withholding tax legislation with European law, particularly where the Member State in question chooses to tax a non-resident investor at a higher rate than a comparable resident investor. This has led to a vast number of claims being filed against EU Member States by portfolio investors, both within and outside the EU.

Although there have been prior decisions from the European Court Justice (ECJ) relating to certain portfolio investors (e.g. portfolio investments), which are very helpful, the position of certain investment vehicles has not been considered specifically until now. 

Please listen in to a recent webcast where Deloitte's top professionals will help you stay current with ECJ developments, as well as give you guidance and practical insights. 

Specific topics to be covered include:

  • Technical issues and an overview of ECJ case
  • Implications for other countries
  • ASC 740 (formerly FIN 48) considerations
  • U.S. reporting issues for mutual funds, hedge funds, and private equity

As used in this document, “Deloitte” means Deloitte LLP, and its subsidiaries. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting.

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