C-135/24John Cockerill SA v État belge

Domstolens egne nøkkelord

Reference for a preliminary ruling – Common system of taxation applicable in the case of parent companies and subsidiaries of different Member States – Directive 2011/96/EU – Article 1(4) – Prevention of tax evasion, tax fraud or abuse – Article 4(1) – Prohibition on taxing profits received – Direct effect – Inclusion of the dividend distributed by the subsidiary in the parent company’s tax base – Deduction of the distributed dividend from the tax base of the parent company – Limitation of the deduction – Intra-group transfer scheme allowing profits made by certain companies to be transferred to others.

Tolker