This article examines the Denkavit Internationaal case in the context of the handful landmark cases in which the European Court of Justice (ECJ) has developed its comprehensive interpretation of the impact of the freedom of establishment and the free movement of capital on the complex taxation of cross-border dividend flows. After considering the fundamental principle of equal treatment and the fundamental principles of the Internal Market, it discusses successively principles and recent case law of home state equal tax treatment of EU and domestic dividends received by resident companies and by resident individual shareholders, source state equal tax treatment of domestic dividends received by resident and non-resident EU companies and by resident and non-resident EU individual shareholders.