By the end of September, the Independent Finance Board (UFS) has submitted to the ECJ two preliminary ruling requests regarding the taxation of foreign portfolio dividends. The preliminary ruling was mainly caused by the fact that the credit method, which, according to the conclusion of the Austrian Supreme Administrative Court (VwGH), applies to foreign portfolio dividends, overburdens the taxpayer with immense documentation, especially with regard to the foreign corporate income tax. As accurate documentation is difficult or even impossible to provide, in many cases – as opposed to the exemption method – economic double taxation is likely to remain. Following the documentation issue, the UFS questions if the application of the credit method in the course of the taxation of portfolio dividends derived from EU countries and third countries is in conflict with Community law. Additionally, the UFS addresses the questions if, in case the ECJ concludes that the application of the credit method is in line with Community law, member states are obliged to allow a carry-forward of tax credit for taxes paid abroad.