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Case C-295/21: Judgment of the Court (Eighth Chamber) of 20 October 2022 (request for a preliminary ruling from the Cour d’appel de Bruxelles — Belgium) — Allianz Benelux SA v État belge, SPF Finances (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)

ECLI:EU:UNKNOWN:62021CA0295

62021CA0295

October 20, 2022
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12.12.2022

Official Journal of the European Union

C 472/13

(Case C-295/21) (*)

(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)

(2022/C 472/15)

Language of the case: French

Referring court

Parties to the main proceedings

Applicant: Allianz Benelux SA

Defendant: État belge, SPF Finances

Operative part of the judgment

Article 4(1) of Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States

must be interpreted as not precluding legislation of a Member State which provides that dividends received by a company are to be included in its basis of assessment before up to 95 % of the total amount is deducted from it and which makes it possible, where appropriate, to carry that deduction forward to subsequent tax years, but which, nonetheless, where that company is absorbed in the context of a merger, limits the transfer of the carry-forward of that deduction to the absorbing company in proportion to the share represented by the net tax assets of the absorbed company in the total of the net tax assets of the absorbing company and the absorbed company.

(*) Language of the case: French.

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