The European Commission, by W. Roels and L. Pamukcu, acting as Agents,Īfter hearing the Opinion of the Advocate General at the sitting on 19 January 2017, The Italian Government, by G. Palmieri, acting as Agent, and by E. De Bonis, avvocato dello Stato, The Spanish Government, by A. Rubio González and V. Ester Casas, acting as Agents, The German Government, by T. Henze and R. Kanitz, acting as Agents, The Danish Government, by C. Thorning and M. Wolff, acting as Agents, The French Government, by D. Colas and S. Ghiandoni, acting as Agents, Having regard to the written procedure and further to the hearing on 30 November 2016,Īfter considering the observations submitted on behalf of:Įqiom SAS and Enka SA, by R. Alberti, avocat, Registrar: V. Giacobbo-Peyronnel, Administrator, Ministre des Finances et des Comptes publics,Ĭomposed of E. Regan, President of the Chamber, A. Arabadjiev and C.G. Fernlund (Rapporteur), Judges, REQUEST for a preliminary ruling under Article 267 TFEU from the Conseil d’État (Council of State, France), made by decision of 30 December 2015, received at the Court on 6 January 2016, in the proceedings (Reference for a preliminary ruling - Direct taxation - Freedom of establishment - Free movement of capital - Withholding tax - Directive 90/435/EEC - Article 1(2) - Article 5(1) - Exemption - Dividends distributed by a resident subsidiary to a non-resident parent company controlled directly or indirectly by one or more residents of third States - Presumption - Fraud, tax evasion and abuse) Reference for a preliminary ruling - Direct taxation - Freedom of establishment - Free movement of capital - Withholding tax - Directive 90/435/EEC - Article 1(2) - Article 5(1) - Exemption - Dividends distributed by a resident subsidiary to a non-resident parent company controlled directly or indirectly by one or more residents of third States - Presumption - Fraud, tax evasion and abuse. Request for a preliminary ruling from the Conseil d'État (France). Judgment of the Court (Sixth Chamber) of 7 September 2017.Įqiom SAS, formerly Holcim France SAS and Enka SA v Ministre des Finances et des Comptes publics. Judgment of the Court (Sixth Chamber) of 7 September 2017.#Eqiom SAS, formerly Holcim France SAS and Enka SA v Ministre des Finances et des Comptes publics.#Request for a preliminary ruling from the Conseil d'État (France).#Reference for a preliminary ruling - Direct taxation - Freedom of establishment - Free movement of capital - Withholding tax - Directive 90/435/EEC - Article 1(2) - Article 5(1) - Exemption - Dividends distributed by a resident subsidiary to a non-resident parent company controlled directly or indirectly by one or more residents of third States - Presumption - Fraud, tax evasion and abuse.#Case C-6/16.
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