The EU Court of Justice issued a judgment in a case regarding application of the EU Parent-Subsidiary Directive, and specifically a withholding tax imposed by Belgium on dividends paid by a subsidiary company of Belgium to its Dutch parent companies that were investment funds (Dutch UCITS). The EU Court of Justice found that neither of the Dutch UCITS entities qualified as a “company of a Member State” for purposes of the Parent-Subsidiary Directive as, while subject to corporate income tax (CIT), the UCITS entities were effectively not taxed and, therefore, the Directive did not preclude Belgium from withholding tax on the dividends.