disqualified refundable imputation tax
as defined in Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global…, Article 3, point (37) (Definitions)
any tax, other than a qualified imputation tax, accrued or paid by a constituent entity that is: (a) refundable to the beneficial owner of a dividend distributed by such constituent entity in respect of that dividend or creditable by the beneficial owner against a tax liability other than a tax liability in respect of such dividend; or (b) refundable to the distributing company upon distribution of a dividend to a shareholder