Case C-575/17: Judgment of the Court (Fifth Chamber) of 22 November 2018 (request for a preliminary ruling from the Conseil d’État — France) — Sofina SA, Rebelco SA, Sidro SA v Ministre de l’Action et des Comptes publics (Reference for a preliminary ruling — Free movement of capital — Withholding tax on the gross amount of nationally sourced dividends paid to non-resident companies — Deferral of taxation of dividends paid to a resident company in the event of a loss-making year — Difference in treatment — Justification — Comparability — Balanced distribution of the powers of taxation between the Member States — Effective collection of tax — Proportionality — Discrimination)