C-102/05Skatteverket v A and B

Domstolens egne nøkkelord

First subparagraph of Article 104(3) of the Rules of Procedure - Free movement of capital - Freedom of establishment - Taxation - Dividends paid in respect of shares distributed by a 'close company'- 'Wage rules' - Taxation of those dividends as income from assets - Calculation of a flat-rate yield - Percentage of capital invested and fraction of salaries - Branch established in a third country - Failure to take into account employees' wages at this branch.

Tolker