This is an Opinion Statement prepared by the ECJ Task Force of the Confédération Fiscale Européenne (CFE)concerning outbound dividends issued on the occasion of the Commission v. Italy case (C-540/07). Advocate General Juliane Kokott delivered her Opinion on 16 July 2009 and the ECJ decided the case on 19 November 2009. The CFE is the leading European association of 32 national tax advisory organisations representing over 180,000 tax advisers.