On December 10, 1997 the Supreme Administrative Court rendered its first decision in a treaty shopping case. In this very first case the court abrogated a decision of the Austrian tax administration by which treaty benefits had been denied to a Dutch base company under the anti-abuse doctrine. However, in a subsequent decision rendered on July 26, 2000 in a treaty shopping case involving a Swiss holding company the court held that it is justified to refuse the refund of the Austrian dividend tax to that holding company, which was a letter box entity, if the company is not prepared to disclose its true beneficiaries. It is interesting to note that the Swiss company was examined by the Swiss tax authorities and, as a result, had received certification that it meets the criteria of the Swiss Federal Council's decision of 1962 of not being an abusive entity and therefore of being entitled to obtain treaty benefits.