ECJ : Greek income tax provision is a withholding within the meaning of the Parent-Subsidiary Directive

Journal
European Taxation 2002 (Volume 42), No. 2
Commentary on the ECJ's decision in the Athenian Breweries case wherein the court found that a Greek provision, whereby tax-free income or income at source at a reduced rate is subject to corporate income tax in proportion to distributed profits, constitutes a withholding tax within the meaning of the EC Parent-Subsidiary Directive.