Santander (Joined Cases C-338/11 to C-347/11): No Withholding Tax on Dividends Paid to Most Foreign UCITS

This note comments on the recent decision of the European Court of Justice in Santander (Joined Cases C-338/11 to C-347/11), which addresses the issue of the freedom of capital and the French tax authorities’ subsequent decision to abolish withholding tax on dividends paid by French companies to most foreign UCITS.