Request for a preliminary ruling from the Conseil d'État in the case Sofina.

Must Articles 56 and 58 TEC, now Articles 63 and 65 TFEU, be interpreted as meaning that the cash-flow disadvantage resulting from the application of withholding tax to dividends paid to loss-making non-resident companies, while loss-making resident companies are not taxed on the amount of the dividends they receive until the year when, if at all, they return to a surplus, constitutes in itself a difference in treatment characterising a restriction on the free movement of capital? 



Informatiesoort: Nieuws

Rubriek: Europees belastingrecht

H&I: Previews


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