C-545/19AllianzGI-Fonds AEVN v Autoridade Tributária e Aduaneira

Domstolens egne nøkkelord

Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Taxation of dividends paid to undertakings for collective investment (UCIs) – Resident and non-resident UCIs – Difference in treatment – Withholding tax imposed solely on dividends paid to non-resident UCIs – Comparability of the situations – Assessment – Account to be taken of the tax regime applicable to shareholders or unitholders in UCIs and of whether resident undertakings are subject to other taxes – None.

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