Judgment_paragraph 23 · Eqiom SAS, formerly Holcim France SAS and Enka SA v Ministre des Finances et des Comptes publics (C-6/16)

23By precluding Member States from imposing withholding tax on the profits distributed by a resident subsidiary to its non-resident parent company, Article 5(1) of the Parent-Subsidiary Directive limits the powers of the Member States regarding the taxation of profits distributed by companies established in their territory to companies established in another Member State (see, to that effect, judgment of 1 October 2009, Gaz de France — Berliner Investissement, C‑247/08, EU:C:2009:600, paragraph 38).