C-67/22Pharol, SGPS, SA v Autoridade Tributária e Aduaneira

Domstolens egne nøkkelord

Reference for a preliminary ruling – Article 99 of the Rules of Procedure of the Court of Justice – Articles 63 and 65 TFEU – Free movement of capital – Tax on the income of legal persons – Dividends received from a company established in the Member State of the beneficiary company – Dividends received from a company established in a third country – National legislation for the elimination of double taxation – Difference in treatment – Restriction – Justification – Efficiency of fiscal verification – Absence of a convention obligation on communicating tax information.

Tolker