On 17 March 2022, the Court of Justice of the European Union (CJEU) issued its judgment in Case C-545/19 concerning Portugal's differing tax treatment of dividends paid to resident and non-resident collective investment undertakings, and whether such differing treatment constitutes a restriction on the free movement of capital in violation of EU law (Article 63 TFEU). Under its domestic law, Portugal taxes non-resident collective investment undertakings through a conventional withholding tax at source in cases where the undertakings concerned are not subject to corporation tax or are subject to a low rate of corporation tax in their State of residence....