Interest and Royalties Directive (2003/49): Court of Appeal Denies Withholding Tax Refund on Interest Due to Lack of Attestation at Time of Payment

In this note, the author comments on a decision of the Court of Appeal of Ghent of 18 March 2014 concerning the application of the Interest and Royalties Directive (2003/49) and the consequences of not adhering to the required Belgian formalities at the time of payment.