On 14 December 2006, The European Court of Justice (ECJ) gave its decision in the case Denkavit International BV, Denkavit France SARL v. Ministre de l'Économie, des Finances et de l'Industrie (C-170/05) to the effect that the French withholding tax on outbound dividends is incompatible with the freedom of establishment set out in Art. 43 of the EC Treaty. The French Supreme Administrative Court had requested a preliminary ruling from the ECJ on 15 December 2004). The ECJ generally followed the Opinion of the Advocate General (AG) Geelhoed of 27 April 2006 and referred extensively to its decision in Test...