DO E.U. TAX TREATIES APPLY TO LIECHTENSTEIN?
Will Liechtenstein registered companies with participations in EC countries benefit from European Court of Justice (ECJ) judgements? Is this the end of dividend withholding taxes, even if Liechtenstein does not have any double tax treaty, apart from that one with Austria? Is this the end of double tax treaties at all in order to minimize double taxation for dividend payments? ECJ Judgement C-170/05 (Denkavit French withholding tax case): Article 43 EC and Article 48 EC preclude national legislation which, in imposing a liability to tax on dividends paid to a non-resident parent company and allowing resident parent companies almost full exemption from such tax, constitutes a discriminatory restriction on freedom of establishment. The ECJ stated that differences in the tax treatment of dividends between parent companies, based on the location of their registered office, constitutes a restriction on freedom of establishment, which is prohibited by the EC Treaty and incapable of justificat
