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.
Authors
- PJ Wouters
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
- 0.00