69A non-resident UCI may have shareholders or unitholders with tax residence in Portugal over whose income that Member State exercises its power of taxation. In that respect, a non-resident UCI is in a situation that is objectively comparable to that of a UCI resident in Portugal (see, by analogy, judgment of 21 June 2018, Fidelity Funds and Others, C‑480/16, EU:C:2018:480, paragraph 61).
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