H&I 2009, 10.2
KBC Bank NV and Beleggen, Risicokapitaal, Beheer NV. EC law precludes Belgian exemption method for profits received by a Belgian company from its subsidiary in another Member State. ECJ (comments by Jansen)
CJ 04-06-2009, C-439/07
- Instantie
Court of Justice of the European Union
- Datum
4 juni 2009
- Zaaknummer
C-439/07
- JCDI
JCDI:ADS909336:1
- Vakgebied(en)
Belastingrecht algemeen (V)
Essentie
KBC Bank NV and Beleggen, Risicokapitaal, Beheer NV. EC law precludes Belgian exemption method for profits received by a Belgian company from its subsidiary in another Member State. ECJ (comments by Jansen)
Samenvatting
At stake is the application of the Belgian dividend deduction regime which limits the deduction to the amount of profits for the tax period in question and consequently, does not allow a carry-over of the unused portion. The facts of the present case are identical to those presented in the Cobelfret case (ECJ 12 February 2009, C-138/07) with the difference that Cobelfret did not include ... Verder lezen? Log in om dit document te bekijken.