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 The Court of Justice of the European Union (CJEU) should clarify in a subsequent ruling that it repealed the Société Générale (C-17/14) ruling in full because a full repeal would contribute most to the development of the EU internal market.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.
EC Tax Review