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 States of EU or EEA – Difficulties related to the proof of corporate tax paid upstream abroad – Lack of exemption and imputation for dividends from third countries – Possible justifications – Proportionality – Consistent and systematic pursuit of the stated objective
C-437/08, [2011] EUECJ C-437/08
Bailii
European
Cited by:
See Also – Haribo Lakritzen Hans Riegel BetriebsgmbH and Another v Linz ECJ 10-Feb-2011
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 . .
Lists of cited by and citing cases may be incomplete.
Updated: 10 August 2021; Ref: scu.426019