C-312/22FL v Autoridade Tributária e Aduaneira

Domstolens egne nøkkelord

Reference for a preliminary ruling – Article 56 EC – Free movement of capital – Personal income tax – Taxation of interest income from bonds and debt instruments – Interest due and paid by entities not resident in the national territory – Difference in treatment according to the place of establishment of the issuing entity and the paying entity for the interest concerned – Agreement between the European Community and the Swiss Confederation providing for measures equivalent to those laid down in Directive 2003/48/EC – Article 2(4) – Taxation of savings income in the form of interest payments from a Swiss source – Obligation to apply the same tax rates as those applied to similar domestic income.

Tolker