Reference : Opinion Statement ECJ-TF 3/2019 on the ECJ Decision of 22 November 2018 in Sofina (Ca...
Scientific journals : Article
Law, criminology & political science : Tax law
Law, criminology & political science : European & international law
Law / European Law
Opinion Statement ECJ-TF 3/2019 on the ECJ Decision of 22 November 2018 in Sofina (Case C-575/17) on Withholding Taxes, Losses, and Territoriality
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
Garcia Prats, Alfredo []
Heydt, Volker []
Kemmeren, Eric []
Kofler, Georg []
Lang, Michael []
Lüdicke, Jürgen []
Nogueira, Joao []
Pistone, Pasquale []
Räder, Albert []
Raventos-Calvo, Stella []
Rust, Alexander []
Shiers, Rupert []
Richelle, Isabelle []
European Taxation
International Bureau of Fiscal Documentation
Yes (verified by ORBilu)
[en] withholding taxes ; tax losses ; principle of territoriality ; freedom of capital movement
[en] This CFE Opinion Statement, submitted to the EU Institutions on 10 October 2019, comments on the Decision in Sofina (Case C-575/17), in respect of which the Fifth Chamber of the ECJ delivered its decision on 22 November 2018. The Court held that the imposition of French dividend withholding tax violated the freedom of capital movement in light of the non- resident’s overall loss situation.
Researchers ; Professionals ; Students

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