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The fundamental freedoms and the taxation of dividends received by non-resident investment funds some thoughts on non-discrimination with a special focus on recent ECJ case law Moritz Scherleitner

By: Scherleitner, Moritz.
Material type: ArticleArticleSubject(s): FONDOS DE INVERSION | DIVIDENDOS | NO RESIDENTES | IMPUESTOS | DISCRIMINACION | LIBERTADES FUNDAMENTALES | UNION EUROPEA | TRIBUNAL DE JUSTICIA DE LAS COMUNIDADES EUROPEAS | JURISPRUDENCIA In: Intertax v. 50, n. 6-7, June-July 2022, p. 484-498Summary: This article discusses outbound cases involving investment funds focusing particularly on the issue of discrimination. The significance of investment fund increased, as well as the number of ECJ cases dealing with fundamental freedoms in this field. In this respect, the author closer examines the ECJ cases Fidelity (C-480/16) and Köln-Aktie Deka Funds (C-156/17), and the AG's opinions A SCPI (C-342/20) and Allianzgi (C-545/19).
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Resumen.

This article discusses outbound cases involving investment funds focusing particularly on the issue of discrimination. The significance of investment fund increased, as well as the number of ECJ cases dealing with fundamental freedoms in this field. In this respect, the author closer examines the ECJ cases Fidelity (C-480/16) and Köln-Aktie Deka Funds (C-156/17), and the AG's opinions A SCPI (C-342/20) and Allianzgi (C-545/19).

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