In a judgment given in September 2004 (C-319/02) in the so-called Manninen case, the European Court of Justice (ECJ) concluded that the Finnish imputation credit ( avoir fiscal) system for dividend taxation was incompatible with the principle of free movement of capital within the European Union (EU). Even before the judgment, the Finnish Parliament decided to abolish the imputation credit system from the beginning of 2005. However, the judgment raises serious concerns over its possible retroactive effect.
The Finnish Imputation Credit System (avoir fiscal)
