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SEPTEMBER 17, 2026 • 16 minute read

iShares Europe ETF (C-139/25): the CJEU draws the line between real and theoretical tax neutralization

The Court of Justice of the European Union has delivered its judgment in iShares Europe ETF (C-139/25), concerning the Spanish taxation of dividends received by a US investment fund. The case adds a new question to the CJEU's extensive case law on discriminatory withholding taxation of non-resident investment funds: can a restriction on the free movement of capital be neutralized on the ground that a foreign fund could have chosen a tax treatment in its state of residence under which it would have been able to credit the source-state tax, even though it did not make that choice?

Stay updated on global withholding tax changes, rates, treaties, reclaims, and litigation

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