ECJ Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Article 49 TFEU – Freedom of establishment – Tax on income of natural persons – Mechanism capping direct taxes by reference to income – Bilateral tax agreement for avoidance of double taxation – Taxation of dividends distributed by a company established in another Member State and already subject to a withholding tax – Failure to take into account or partial taking into account of the tax paid in the other Member State for the calculation of the tax cap – Article 65 TFEU – Restriction – Justification
T. von Danwitz, P
C-375/12, [2014] EUECJ C-375/12
Bailii
European
Updated: 01 December 2021; Ref: scu.522478