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Opinion of Advocate General Pikamäe delivered on 13 July 2023.
Cofidis v Autoridade Tributária e Aduaneira.
Request for a preliminary ruling from the Tribunal Arbitral Tributário (Centro de Arbitragem Administrativa - CAAD).
Reference for a preliminary ruling – Direct taxation – Article 49 TFEU – Freedom of establishment – Introduction of a tax on the liabilities of credit institutions for the purpose of funding the national social security system – Alleged discrimination against branches of foreign credit institutions – Directive 2014/59/EU – Framework for the recovery and resolution of credit institutions and investment firms – Scope.
Case C-340/22.

Court reports – general – 'Information on unpublished decisions' section

ECLI identifier: ECLI:EU:C:2023:584

Judgment of the Court (Fourth Chamber) of 16 June 2022.
ACC Silicones Ltd. v Bundeszentralamt für Steuern.
Request for a preliminary ruling from the Finanzgericht Köln.
Reference for a preliminary ruling – Free movement of capital – Dividends from ‘free-float’ shares – Reimbursement of tax on income from capital paid by a non-resident company – Conditions – Free movement of capital – Principle of proportionality.
Case C-572/20.

ECLI identifier: ECLI:EU:C:2022:469

Opinion of Advocate General Collins delivered on 20 January 2022.
ACC Silicones Ltd. v Bundeszentralamt für Steuern.
Request for a preliminary ruling from the Finanzgericht Köln.
Reference for a preliminary ruling – Free movement of capital – Dividends from ‘free-float’ shares – Reimbursement of tax on income from capital paid by a non-resident company – Conditions – Free movement of capital – Principle of proportionality.
Case C-572/20.

ECLI identifier: ECLI:EU:C:2022:48

Opinion of Advocate General Saugmandsgaard Øe delivered on 6 October 2021.

Court reports – general

ECLI identifier: ECLI:EU:C:2021:823

Opinion of Advocate General Rantos delivered on 30 September 2021.

; Court reports – general – 'Information on unpublished decisions' section

ECLI identifier: ECLI:EU:C:2021:779

Order of the Court (Sixth Chamber) of 21 January 2020.
Estado do Canadá v Autoridade Tributária e Aduaneira.
Request for a preliminary ruling from the Tribunal Tributário de Lisboa.
Reference for a preliminary ruling — Article 99 of the Rules of Procedure of the Court of Justice — Restrictions on the free movement of capital to or from a third country — Direct taxation — Tax on the revenue of legal persons — Profits distributed by companies resident in the territory of Portugal — Reduction in the tax base.
Case C-613/18.

ECLI identifier: ECLI:EU:C:2020:19

Opinion of Advocate General Wathelet delivered on 27 September 2018.

Court reports – general – 'Information on unpublished decisions' section

ECLI identifier: ECLI:EU:C:2018:779

Opinion of Advocate General Wathelet delivered on 7 August 2018.
Sofina SA and Others v Ministre de l'Action et des Comptes publics.
Request for a preliminary ruling from the Conseil d'État (France).
Reference for a preliminary ruling — Free movement of capital — Withholding tax on the gross amount of nationally sourced dividends paid to non-resident companies — Deferral of taxation of dividends paid to a resident company in the event of a loss-making year — Difference in treatment — Justification — Comparability — Balanced distribution of the powers of taxation between the Member States — Effective collection of tax — Proportionality — Discrimination.
Case C-575/17.

Court reports – general – 'Information on unpublished decisions' section

ECLI identifier: ECLI:EU:C:2018:650

Opinion of Advocate General Mengozzi delivered on 20 December 2017.
Fidelity Funds and Others v Skatteministeriet.
Request for a preliminary ruling from the Østre Landsret.
Reference for a preliminary ruling — Free movement of capital and liberalisation of payments — Restrictions — Taxation of dividends paid to undertakings for collective investment in transferable securities (UCITS) — Dividends paid by companies resident in one Member State to non-resident UCITS — Tax exemption for dividends paid by companies resident in one Member State to resident UCITS — Justifications — Balanced allocation between Member States of the power to impose taxes — Coherence of the tax system — Proportionality.
Case C-480/16.

Court reports – general – 'Information on unpublished decisions' section

ECLI identifier: ECLI:EU:C:2017:1015

Judgment of the Court (Fourth Chamber) of 21 December 2016.
European Commission v Portuguese Republic.
Failure of a Member State to fulfil obligations — Articles 21 TFEU, 45 TFEU and 49 TFEU — Articles 28 and 31 of the Agreement on the European Economic Area — Freedom of movement for persons — Freedom of movement for workers — Freedom of establishment — Taxation of natural persons on capital gains resulting from a share exchange — Taxation of natural persons on capital gains resulting from a transfer of all the assets used in the exercise of a business or professional activity — Exit taxation of individuals — Immediate recovery of taxation — Difference in treatment between natural persons who exchange shares and maintain their residence in the national territory and those who make such an exchange and transfer their residence to the territory of another Member State of the European Union or the European Economic Area — Difference in treatment between natural persons transferring all the assets related to an activity carried out on an individual basis to a company with its head office and effective management in Portugal and those who carry out such a transfer to a company with its head office or its effective management in the territory of another Member State of the European Union or of the European Economic Area — Proportionality.
Case C-503/14.

Court reports – general

ECLI identifier: ECLI:EU:C:2016:979