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Case C-585/22, Staatssecretaris van Financiën (Interest in respect of an intra-group loan): Judgment of the Court (First Chamber) of 4 October 2024 (request for a preliminary ruling from the Hoge Raad der Nederlanden – Netherlands) – X BV v Staatssecretaris van Finaciën (Reference for a preliminary ruling – Freedom of establishment – Article 49 TFEU – Corporation tax – Intra-group cross-border loan for the purposes of financing the acquisition or the extension of an interest in a company not related to the group concerned that becomes, as a result of that transaction, related to that group – Deduction of interest paid on that loan – Loan contracted on an arm’s length basis – Concept of wholly artificial arrangement – Principle of proportionality)
ECLI:EU:UNKNOWN:62022CA0585
62022CA0585
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Official Journal of the European Union
C series
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C/2025/875
17.2.2025
(Case C-585/22, (1) Staatssecretaris van Financiën (Interest in respect of an intra-group loan))
(Reference for a preliminary ruling - Freedom of establishment - Article 49 TFEU - Corporation tax - Intra-group cross-border loan for the purposes of financing the acquisition or the extension of an interest in a company not related to the group concerned that becomes, as a result of that transaction, related to that group - Deduction of interest paid on that loan - Loan contracted on an arm’s length basis - Concept of ‘wholly artificial arrangement’ - Principle of proportionality)
(C/2025/875)
Language of the case: Dutch
Referring court
Parties to the main proceedings
Applicant: X BV
Defendant: Staatssecretaris van Financiën
Operative part of the judgment
must be interpreted as:
not precluding national legislation under which, in the determination of a taxpayer’s profits, the deduction of interest paid in respect of a loan debt contracted with a related entity, relating to the acquisition or extension of an interest in another entity which becomes, as a result of that acquisition or extension, an entity related to that taxpayer is to be refused in full, where that debt is considered to constitute a wholly artificial arrangement or is part of such an arrangement, even if that debt was incurred on an arm’s length basis and the amount of that interest does not exceed that which would have been agreed between independent undertakings.
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Language of the case: Dutch.
ELI: http://data.europa.eu/eli/C/2025/875/oj
ISSN 1977-091X (electronic edition)
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