On 8 May 2008, Advocate General (AG) Eleanor Sharpston of the European Court of Justice (ECJ) gave her opinion in the case of Belgische Staat v. Cobelfret NV (C-138/07). Details of the opinion are summarized below. (a) Facts. In each year from 1992 to 1998, Cobelfret NV (Cobelfret), a company established in Belgium, received dividends from its holdings in both Belgium and the United Kingdom. It is understood that Cobelfret and its relevant subsidiaries qualify as a parent company and subsidiaries within the meaning of the Parent_Subsidiary Directive 90/435/EEC (Directive). In 1994, 1995 and 1997, Cobelfret suffered losses and could,...