The Court of Justice of the European Union (CJEU) issued a judgment on 13 November 2019 on whether Germany's final withholding tax on dividends paid to non-resident pension funds violates EU law in relation to the free movement of capital. The case concerned a Canadian pension fund that received dividends from portfolio investments in German public limited companies during the years 2007 to 2010, which were subject to final withholding tax at a rate of 15% (rate under Canada-Germany tax treaty). The Canadian pension fund applied for a refund of the tax, claiming that the final withholding was discriminatory given...