14 Sep 2017 (Case C-628/15); EU:C:2017:687; [2018] Ch 230; [2018] 2 WLR 1405; [2017] STC 2075; [2017] WLR(D) 598, ECJ (President of Chamber M Ilešič, Judges A Prechal, A Rosas, C Toader, E Jarašiūnas Advocate General M Wathelet)
EUROPEAN UNION — Free movement of capital — Revenue — Corporation tax — Differential tax treatment of nationally-sourced and foreign-sourced dividends by member state having system for preventing or mitigating series of charges to tax — Pension fund trustees exempt from United Kingdom tax — United Kingdom-resident companies distributing foreign-sourced dividends to trustees in relation to which no entitlement to tax credits — Whether contrary to European Union law — Whether shareholders, resident in same member state as distributing company, enjoying European Union right to free movement of capital — Whether domestic law required to provide remedies to shareholders — Income and Corporation Taxes Act 1988 (c 1), s 246C (as inserted by Finance Act 1994 (c 9), s 138, Sch 16, para 1) — FEU Treaty, art 63FEU
(Case C-628/15); EU:C:2017:687; [2018] Ch 230; [2018] 2 WLR 1405; [2017] STC 2075; [2017] WLR(D) 598, ECJ
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