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Case C-458/18: Judgment of the Court (Fifth Chamber) of 2 April 2020 (request for a preliminary ruling from the Administrativen sad Sofia-grad — Bulgaria) — ‘GVC Services (Bulgaria)’ EOOD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ — Sofia (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 2(a)(i) and (iii), and Annex I, Part A(ab) and the last indent of Part B — Concepts of ‘companies incorporated under United Kingdom law’ and ‘United Kingdom corporation tax’ — Companies registered in Gibraltar which are subject to corporation tax there)
ECLI:EU:UNKNOWN:62018CA0458
62018CA0458
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Official Journal of the European Union
C 222/9
(Case C-458/18) (1)
(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 2(a)(i) and (iii), and Annex I, Part A(ab) and the last indent of Part B - Concepts of ‘companies incorporated under United Kingdom law’ and ‘United Kingdom corporation tax’ - Companies registered in Gibraltar which are subject to corporation tax there)
(2020/C 222/08)
Language of the case: Bulgarian
Referring court
Parties to the main proceedings
Applicant: ‘GVC Services (Bulgaria)’ EOOD
Defendant: Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ — Sofia
Operative part
Article 2(a)(i) and (iii) of Council Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, read in conjunction with Part A(ab) and the last indent of Part B of Annex I to that directive, must be interpreted as meaning that the concepts ‘companies incorporated under United Kingdom law’ and ‘corporation tax in the United Kingdom’ in those provisions do not cover companies incorporated in Gibraltar which are subject to corporation tax there.
(1)
OJ C 341 of 24.9.2018.
Language of the case: Bulgarian
ECLI:EU:C:2020:140