Judgment of the Court (Sixth Chamber) of 27 November 2025.#Santander Renta Variable España Pensiones, Fondo de Pensiones v Autoridade Tributária e Aduaneira.#Reference for a preliminary ruling – Article 63 TFEU – Free movement of capital – Taxation – Corporation tax on dividends – Legal person governed by Spanish law, taxable person not resident in Portugal – Withholding tax – Exemption – Standard of proof – Certificate attesting that the conditions for exemption are satisfied – Article 65 TFEU – Overriding reasons in the public interest – Effectiveness of fiscal supervision – Effective collection of tax – Cooperation and mutual assistance between the competent authorities of the Member States.#Case C-525/24.