C-525/24Santander Renta Variable España Pensiones, Fondo de Pensiones v Autoridade Tributária e Aduaneira

Domstolens egne nøkkelord

Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Taxation – Corporation tax on dividends – Legal person governed by Spanish law, taxable person not resident in Portugal – Withholding tax – Exemption – Standard of proof – Certificate attesting that the conditions for exemption are satisfied – Article 65 TFEU – Overriding reasons in the public interest – Effectiveness of fiscal supervision – Effective collection of tax – Cooperation and mutual assistance between the competent authorities of the Member States.

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