70It is true that the Portuguese Republic cannot tax non-resident shareholders or unitholders on the dividends distributed by non-resident UCIs, as the Portuguese Government has, moreover, acknowledged both in its written observations and in reply to the questions put to it by the Court. However, the absence of such a possibility is consistent with the logic of moving the level of taxation from the vehicle to the shareholder or unitholder (see, by analogy, judgment of 21 June 2018, Fidelity Funds and Others, C‑480/16, EU:C:2018:480, paragraph 62).
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