Advocate General Trstenjak handed down her opinion in the Meilicke case on 13 January 2011. This case was concerned with the availability of tax credits for foreign tax. The Advocate General concluded that a tax credit needed to be given for the amount of tax actually paid up to the limit of the domestic corporation tax rate. To require a certificate for foreign corporation tax to be in the form prescribed by domestic law breached the principle of effectiveness if it was in fact impossible or excessively difficult to obtain such a certificate. Tax paid at a level lower than that of the foreign company making the distribution needs to be taken into account in so far as tax paid at a lower level in domestic situations also impacts on the level of credit extended to shareholders.