On 22 November 2018, the Court of Justice of The European Union (CJEU) issued its judgment concerning whether the differing French tax treatment of dividend income of a resident company versus a non-resident company constitutes a restriction on the free movement of capital in violation of EU law. The case involved three Belgium-based companies, Sofina SA, Rebelco SA, and Sidro SA, which received dividends as shareholders in French companies between 2008 and 2011. Since these financial years were loss-making for the Belgian companies, they claimed a refund of the tax withheld on the dividends. The basis of the claim was...