Judgment of the Court (Sixth Chamber) of 19 December 2024.#Credit Suisse Securities (Europe) Ltd v Diputación Foral de Bizkaia.#Request for a preliminary ruling from the Tribunal Superior de Justicia del País Vasco.#Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Taxation – Taxation of dividends – Withholding tax – Reimbursement of withholding tax, granted to resident dividend recipients that are loss-making at the end of the tax year in which the dividends are received – No reimbursement of the withholding tax to non-resident dividend recipients – Difference in treatment – Restriction – Comparability – Justification.#Case C-601/23.