Part 1 - AL-Tax

226Table 9.3(Continued)Classical system (unmodified – modified) Imputation system Participation exemption(partial – full)Germany Individuals: Taxed 50% of the dividend received. Corporate shareholders: 95%.Greece All kinds of shareholders: 100%.Ireland Individuals: Dividends are generally liable to income tax Corporate shareholders: 100%.at the individual’s marginal income tax rate; Credit isgiven for the dividend withholding tax paid on thesedividends and a refund of the withholding will be madeto the extent it exceeds the income tax liability thereon.Italy Qualified individuals and individuals who hold the Corporate shareholders: 95%.participation in a business capacity: 60% exemption.Other individuals: Final withholding tax at a rateof 12.5%.Luxembourg Individuals and minority shareholders: 50% of Majority corporate shareholders:dividends and other profit distributions are exempt. 100%.Netherlands Individual substantial shareholding: Flat rate of 25%. Substantial corporateIndividuals who hold the participation in a business shareholders: 100%.capacity and portfolio corporate shareholders: Taxed atprogressive rates up to 52%.Other individuals: Annual fixed yield of 4% of theaverage economic value of the investment. This fixedyield is taxed at a flat rate of 30%.