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Court of Justice of the European Union · Judgment

C-203/25„NEO GROUP“ UAB v Valstybinė mokesčių inspekcija prie Lietuvos Respublikos finansų ministerijos

Decided
2026-10-15
ECLI
ECLI:EU:C:2026:863
CELEX
62025CJ0203
Finality
Final, the decision cannot be appealed

Also searched as: Case C-203/25, C-203/25 2026, ECLI:EU:C:2026:863.

The court's own keywords

Reference for a preliminary ruling – Taxation – Directive 2011/96/EU – Common system of taxation applicable in the case of parent companies and subsidiaries of different Member States – Exemption from withholding tax on dividends distributed by a resident subsidiary to a non-resident parent company – Article 1(2) and (3) – Anti-abuse provision – Non-genuine arrangement – Steps of an arrangement – Chain of transactions – Objective analysis of all relevant facts and circumstances – Beneficial owner of dividends – Tax advantage – Lack of relevance of the Member State or of the stage where that advantage is obtained – Subjective element – Proof of its existence with regard to one of the participants in the chain of transactions concerned – Principle of proportionality – Bilateral convention for the avoidance of double taxation.

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    Summary: Final, the decision cannot be appealed

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    eu:c-203-25

    Read from EU:s publikationsbyrå, Cellar (EUR-Lex och CURIA) on 2026-08-22.

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