C-601/23Credit Suisse Securities (Europe) Ltd v Diputación Foral de Bizkaia

Domstolens egne nøkkelord

Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Taxation – Taxation of dividends – Withholding tax – Reimbursement of withholding tax, granted to resident dividend recipients that are loss-making at the end of the tax year in which the dividends are received – No reimbursement of the withholding tax to non-resident dividend recipients – Difference in treatment – Restriction – Comparability – Justification.

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