C-295/21Allianz Benelux SA v État belge, SPF Finances

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 90/435/EEC – Article 4(1) – Exemption in favour of a parent company of the dividends paid by its subsidiary – Carrying over definitively taxed income surpluses to subsequent tax years – Absorption of a company with definitively taxed income surpluses by another company – National legislation limiting the transfer of those surpluses to the absorbing company.

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