Judgment_paragraph 54 · Test Claimants in Class IV of the ACT Group Litigation v Commissioners of Inland Revenue (C-374/04)

54The mere fact that, for holdings to which Directive 90/435 does not apply, it is for the Member States to determine whether, and to what extent, a series of charges to tax and economic double taxation are to be avoided and, for that purpose, to establish, either unilaterally or through DTCs concluded with other Member States, procedures intended to prevent or mitigate such a series of charges to tax and that economic double taxation, does not of itself mean that the Member States are entitled to impose measures that contravene the freedoms of movement guaranteed by the Treaty.

Test Claimants in Class IV of the ACT Group Litigation v Commissioners of Inland Revenue (C-374/04)

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