The Denkavit Internationaal case and its consequences : the limit between distortion and discrimination?

After describing the facts of the Denkavit case, the author comments on the principles raised in the decision and its effect in relation to the two matters settled by the ECJ : is the French withholding tax on outbound dividends discriminatory and can a tax credit under a tax treaty eliminate discrimination under national law? The author then comments on the practical consequences of the case.