The CFE ECJ Task Force has published an Opinion Statement on Case C-464/14, SECIL, in which the judgment of the 5th Chamber of the Court of Justice of the European Union (ECJ) was delivered on 24 November 2016. The Opinion Statement was submitted to the relevant European Institutions in February 2017.
The case concerned the discriminatory Portuguese taxation of dividends received by corporate shareholders from their subsidiaries in third States, namely in Lebanon and Tunisia. In a clear and instructive judgment, the Court not only clarified the scope and impact of the Treaty provisions on free movement of capital but also the legal ramifications of the Euro-Mediterranean Agreements with Lebanon and Tunisia.
The Opinion Statement is available below.