Answer given by Mr Hoekstra on behalf of the European Commission

13.1.2025

Council Directive 2011/96/EU Parent Subsidiary Directive[1], exempts dividend payments and other profit distributions by subsidiaries to their parent companies from withholding taxes, it also provides for the elimination of double taxation of such income at the level of the parent company.

Share buy-backs, which are not considered as distribution of profits, do not involve transactions under the scope defined in the Parent Subsidiary Directive.

• [1] https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX:32011L0096