The Court of Justice has given a judgment in the case Groupe Steria. Article 49 TFEU must be interpreted as precluding rules of a Member State that govern a tax integration regime under which a tax-integrated parent company is entitled to neutralisation as regards the add-back of a proportion of costs and expenses, fixed at 5% of the net amount of the dividends received by it from tax-integrated resident companies, when such neutralisation is refused to it under those rules as regards the dividends distributed to it from subsidiaries located in another Member State, which, had they been resident, would have been eligible in practice, if they so elected.



Informatiesoort: Nieuws

Rubriek: Europees belastingrecht, Vennootschapsbelasting, Dividendbelasting

H&I: Previews


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