Court of Justice 8 May 2008, C-138/07 (Belgische Staat v Cobelfret NV.)

Opinion of the Advocate-General Opinion of the Advocate-General 1. Article 4(1) of Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (2) (‘the Parent/Subsidiary Directive’ or ‘the Directive’) provides that, where a parent company resident in one Member State receives a dividend from