Asunto C-176/15: Sentencia del Tribunal de Justicia (Sala Sexta) de 30 de junio de 2016 (petición de decisión prejudicial planteada por el Tribunal de première instance de Liège — Bélgica) — Guy Riskin, Geneviève Timmermans/État belge (Procedimiento prejudicial — Libre circulación de capitales — Artículos 63 TFUE y 65 TFUE — Artículo 4 TUE — Fiscalidad directa — Tributación de los dividendos — Convenio bilateral para evitar la doble imposición — Estado tercero — Ámbito de aplicación)
Section | información judicial |
Issuing Organization | Tribunal de Justicia de las Comunidades Europeas |
12.9.2016 ES Diario Oficial de la Unión Europea C 335/16
Lengua de procedimiento: francés
Tribunal de première instance de Liège
Demandantes: Guy Riskin, Geneviève Timmermans
Demandada: État belge
Los artículos 63 TFUE y 65 TFUE, en relación con el artículo 4 TUE, deben interpretarse en el sentido de que no se oponen a que un Estado miembro no extienda, en una situación como la controvertida en el litigio principal, el trato favorable otorgado a un accionista residente por un convenio fiscal bilateral para evitar la doble imposición celebrado entre dicho Estado miembro y un Estado tercero, mediante el cual el impuesto retenido en la fuente por el Estado tercero se deduce de modo incondicional del impuesto debido en el Estado miembro de residencia del accionista, a un accionista residente que...
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