Advocate General Mengozzi handed down his opinion in the Accor case on 22 December 2010. This case is concerned with the French “précompte” (advance payment) system. The AG concluded that in situations where a French parent company can deduct from the advance payment the “avoir fiscal” (tax credit) which attached to dividends received from domestic sources, such a credit should also be given for tax paid on the profits out of which foreign sourced dividends were paid. The tax authority did however not need to grant such a credit in situations in which it could prove that this would lead to an unjust enrichment of the taxpayer. Finally, the Advocate General found that a Member State could ask the taxpayer for proof of the amount of underlying tax paid on the foreign distributed profits, but only if in domestic situations the tax credit was also measured by the amount of tax actually paid and if to adduce such evidence would not be in practice impossible or excessively difficult.