I have a query regarding an individual who is a 25% ordinary shareholder of a company in Belgium (the other shareholder owns the remaining 75% of the company). The company has issued a dividend on the ordinary shares from which 10% withholding tax was deducted. Can our client claim a credit for the underlying tax suffered on the profits used to pay the dividend as well as the withholding tax deducted given that he is a direct investor and not a 'portfolio investor'? If the underlying tax credit can be claimed, can it be based on the Revenue approved rate of 44% or should it be based on actual rate of corporation tax suffered on the profits?
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