Opinion Statement ECJ-TF 2/2021 on the ECJ Decision of 25 February 2021 in Société Générale (Case C-403/19) on the calculation of the maximum amount of a foreign direct tax credit

Resource Information

The work Opinion Statement ECJ-TF 2/2021 on the ECJ Decision of 25 February 2021 in Société Générale (Case C-403/19) on the calculation of the maximum amount of a foreign direct tax credit represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Opinion Statement ECJ-TF 2/2021 on the ECJ Decision of 25 February 2021 in Société Générale (Case C-403/19) on the calculation of the maximum amount of a foreign direct tax credit

Creator

• Shiers, R
• Kemmeren, E.C.C.M
• Kofler, G.W
• Lang, M
• Nogueira, J.F. Pinto
• Raventós-Calvo, S
• Richelle, I
• Rust, A
• García Prats, F.A
• HJI Panayi, C
• Haslehner, W.C
• Heydt, V

Subject

• EU law
• dividend
• double taxation
• foreign source income
• foreign tax credit
• fundamental freedoms
• ECJ case law

Language

eng

Summary

In this CFE Opinion Statement, submitted to the EU Institutions in September 2021, the CFE ECJ Task Force comments on the ECJ decision in Société Générale (Case C-403/19), which reinforces established case law that EU law neither prohibits juridical double taxation nor does it put an obligation on the residence Member State to prevent the disadvantages that could arise from the exercise of competence thus attributed by the two Member States

Citation source

In: European taxation. - Amsterdam. - Vol. 62 (2022), no. 1 ; p. 30-39

Geographic coverage

• European Union
• Europe

Language note

English