The Court of Justice of the European Union (CJEU) issued a judgment on 7 November 2024 in response to a request for a preliminary ruling from the Gerechtshof 's-Hertogenbosch (Court of Appeal, 's-Hertogenbosch, Netherlands) concerning dividend tax on resident and non-resident companies. The case involved XX, a UK-based insurance company, which offers unit-linked insurance contracts mainly to institutional pension insurance companies and employers in the UK. The premiums received from customers are allocated to one or more baskets of unit securities linked to units of account and, in exchange, 'units' are attributed to customers. During the period at issue in...