On 17 November 2016, the opinion of Advocate General Juliane Kokott of the Court of Justice of the European Union (CJEU) was published concerning whether Belgium's Fairness Tax is compatible with both the freedom of establishment under Article 49 of the TFEU and the rules of the EU Parent-Subsidiary Directive (2011/96/EU). While the Advocate General concluded that the Fairness Tax is compatible in most aspects, it is not compatible when it subjects a company to a tax burden that exceeds the a…