Cross-border income (e.g. dividends and interest) is often subject to withholding tax in the source country. However, in accordance with the global income principle, the investor is also liable to pay tax on this income in his country of residence.
The aim must be to avoid a double tax burden in both countries.
Double taxation agreements (so-called DTAs) and European law offer numerous possibilities for avoiding double taxation and optimising the existing tax burden. In the Santander, Aberdeen Finnivest, Fokus Bank and other recent judgements, the ECJ and EFTA Court have ruled that the withholding tax collection practices of various EU states do not comply with European law.