Judgment of the Court of Justice in the case Argenta Spaarbank.

Article 49 TFEU must be interpreted as precluding national legislation under which, for calculation of a deduction granted to a company subject to full tax liability in a Member State, the net value of the assets of a permanent establishment situated in another Member State is not taken into account when the profits of that permanent establishment are not taxable in the first Member State by virtue of a double taxation convention, whereas the assets attributed to a permanent establishment situated in the territory of the first Member State are taken into account for that purpose.

CJ no C-350/11, 4 July 2013


Informatiesoort: Nieuws

Rubriek: Europees belastingrecht, Vennootschapsbelasting, Internationaal belastingrecht

H&I: Previews


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