C-524/23European Commission v Kingdom of Belgium

Domstolens egne nøkkelord

Failure of a Member State to fulfil its obligations – Article 258 TFEU – Directive (EU) 2016/1164 – Rules against tax avoidance practices that directly affect the functioning of the internal market – Article 8(7) – Computation of controlled foreign company income – Requirement to allow the taxpayer to deduct from his or her tax liability the tax paid by the controlled foreign company – Scope – Non-genuine arrangements which have been put in place for the essential purpose of obtaining a tax advantage – Failure to transpose.

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