Free movement of capital – Corporation tax – Exemption of nationally-sourced dividends – Exemption of foreign-sourced dividends only if certain conditions are complied with – Application of an imputation system to non’exempt foreign’sourced dividends – Proof required as to the foreign tax creditable
 EUECJ C-437/08,  STC 917,  EUECJ C-436/08, ECLI:EU:C:2011:61,  2 CMLR 37,  ECR I-355,  STI 528
See Also – Haribo Lakritzen Hans Riegel BetriebsgmbH and Another v Linz ECJ 11-Nov-2010
Free movement of capital – Portfolio participations – Corporate tax – Abolition of economic double taxation of dividends – Exemption of dividends of national origin – Conditional exemption with possible passage to imputation for dividends from other . .
Cited – Prudential Assurance Company Ltd v Revenue and Customs SC 25-Jul-2018
PAC sought to recover excess advance corporation tax paid under a UK system contrary to EU law. It was now agreed that some was repayable but now the quantum. Five issues separated the parties.
Issue I: does EU law require the tax credit to be . .
Lists of cited by and citing cases may be incomplete.
Updated: 10 August 2021; Ref: scu.666509