Opinion of Advocate General Hogan delivered on 19 November 2020.#Proceedings brought by E.#Request for a preliminary ruling from the Korkein hallinto-oikeus.#Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Income tax – Income from capital – Income distributed by a resident undertaking for collective investment in transferable securities (UCITS) constituted in accordance with contract law – Income distributed by a UCITS established in another Member State and constituted in accordance with statute – Difference in treatment – Article 65 TFEU – Objectively comparable situations.#Case C-480/19.