Even if the free movement of capital is considered to be applicable in the present case, may the non-application to the dividends in question of the mechanisms for the elimination or mitigation of economic double taxation provided for in the Portuguese legislation in force at that time be regarded as being justified by the fact that the framework for cooperation established in Council Directive 77/799/EEC of 19 December 1977 concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation does not exist in the case of Tunisia and ...[+++]Lebanon?

Cash demutualization benefits will be treated as dividends eligible for the dividend tax credit.

In the circumstances of the present case, the Commission recognises that the Danish State, during the period 1999-2008, collected additional dividends (compared with what had been budgeted initially) of an overall amount which clearly exceeds DSB’s surplus profits.

Given the pattern of returns to the shareholder (practically all of it resulting from the terminal value and practically nothing from dividends) the Commission believes that a private investor would expect some returns in cash in the [.] years after the investment and would be uneasy that the whole or the predominant share of the return from the investment comes from the terminal value in the [.] year.

Outbound dividends are, in this case, dividends paid by domestic companies to companies in other States.

While it is absolutely desirable to maintain our species at risk, to have them flourish, propagate and multiply in a friendly environment, it is also extremely important that the economic stability of the country be allowed to do just exactly the same; to prosper, to expand, to put people to work so they can make some profit and pay their shareholders and their taxes.