This article examines the cross-border taxation of dividends received by equity funds. In particular, the author examines the issue of discrimination and the related analysis of whether or not domestic and foreign funds are in a comparable situation. In Part 1, published in European Taxation 2/3 (2013), the author examined ECJ and EFTA Court decisions in this area. Part 2 analyses ECJ guidelines and the author's own approach to the comparability analysis and the concept of fiscal coherence.