On 13 July 2016, the Court of Justice of the European Union (CJEU) issued its judgment concerning Portugal's differing tax treatment of interest income received in Portugal by resident and non-resident financial institutions. The case involved Portugal-based Brisal - Auto Estradas do Litoral SA (Brisal) and KBC Finance Ireland (KBC). In 2004, Brisal entered into an external financing agreement with a syndicate of banks, which was later expanded to include KBC. As a non-resident bank, KBC was subject to tax withholding on the gross interest income received in Portugal, while the resident banks that were part of the agreement were...