The author posits that the XX ruling (implicitly) repeals or at least mitigates the outlier ruling Société Générale (C-17/14). The Court of Justice of the European Union (CJEU) should clarify in a subsequent ruling that it repealed the Société Générale (C-17/14) ruling in full because a full repeal would contribute most to the development of the EU internal market. Nevertheless, the ruling contributes to the development of the EU internal market, the creation of a level playing field, the establishment of international tax neutrality, to capital and labour import neutrality (CLIN), the realization of the ability-to-pay and the direct-benefit principles, occasionally to the establishment of an origin-based allocation of tax jurisdiction on dividend income and to a certain extent to the realization of some of the SDGs 1, 8, 10, 16 and 17. Therefore, the author welcomes this ruling.
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Eric C.C.M. Kemmeren
EC Tax Review
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Eric C.C.M. Kemmeren (Sat,) studied this question.
synapsesocial.com/papers/6930dc78ea1aef094cca21c7 — DOI: https://doi.org/10.54648/ecta2025037