Belgian Tax Consolidation Regime Violates EU Parent-Subsidiary Directive (2011/96)

On 13 March 2025, the ECJ ruled that the Belgian tax consolidation rules are incompatible with the EU Parent-Subsidiary Directive (2011/96) insofar as the Belgian rules eliminate the possibility of offsetting group contributions received against the dividend received deduction (John Cockerill (Case C-135/24). The decision is short, but powerful, and applies the methodology that the ECJ developed in the Brussels Securities (Case C-389/18) and Allianz Belgium (Case C-295/21) cases.

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Publication Details

Journal
European Taxation
Published
2025-05-20
DOI
https://doi.org/10.59403/1te5y3q
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
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article

Belgian Tax Consolidation Regime Violates EU Parent-Subsidiary Directive (2011/96)

PJ Wouters
European Taxation
Taxation and Legal Issues
article

Belgian Tax Consolidation Regime Violates EU Parent-Subsidiary Directive (2011/96)

PJ Wouters
article en

Abstract

On 13 March 2025, the ECJ ruled that the Belgian tax consolidation rules are incompatible with the EU Parent-Subsidiary Directive (2011/96) insofar as the Belgian rules eliminate the possibility of offsetting group contributions received against the dividend received deduction (John Cockerill (Case C-135/24). The decision is short, but powerful, and applies the methodology that the ECJ developed in the Brussels Securities (Case C-389/18) and Allianz Belgium (Case C-295/21) cases.

European TaxationVol. 65(6)
Openalex Percentile: Top 84%
Taxation and Legal Issues
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Belgian Tax Consolidation Regime Violates EU Parent-Subsidiary Directive (2011/96) — PJ Wouters · European Taxation (2025) | TGRS Research Map | TGRS