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Case C-135/24, John Cockerill: Judgment of the Court (Sixth Chamber) of 13 March 2025 (request for a preliminary ruling from the Tribunal de première instance de Liège – Belgium) – John Cockerill SA v État belge (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 1(4) – Prevention of tax evasion, tax fraud or abuse – Article 4(1) – Prohibition on taxing profits received – Direct effect – Inclusion of the dividend distributed by the subsidiary in the parent company’s tax base – Deduction of the distributed dividend from the tax base of the parent company – Limitation of the deduction – Intra-group transfer scheme allowing profits made by certain companies to be transferred to others)
ECLI:EU:UNKNOWN:62024CA0135
62024CA0135
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Official Journal of the European Union
C series
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C/2025/2501
12.5.2025
(Case C-135/24,
John Cockerill)
(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 1(4) - Prevention of tax evasion, tax fraud or abuse - Article 4(1) - Prohibition on taxing profits received - Direct effect - Inclusion of the dividend distributed by the subsidiary in the parent company’s tax base - Deduction of the distributed dividend from the tax base of the parent company - Limitation of the deduction - Intra-group transfer scheme allowing profits made by certain companies to be transferred to others)
(C/2025/2501)
Language of the case: French
Referring court
Parties to the main proceedings
Applicant: John Cockerill SA
Defendant: État belge
Operative part of the judgment
Article 1(4) and Article 4(1) 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, as amended by Council Directive (EU) 2015/121 of 27 January 2015,
must be interpreted as precluding legislation of a Member State that provides that dividends received by a parent company from its subsidiary must first be included in the tax base of the subsidiary, before they can subsequently be deducted, without that deduction applying to the amount of an intra-group transfer included in the tax base.
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(1) OJ C C/2024/3313.
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ELI: http://data.europa.eu/eli/C/2025/2501/oj
ISSN 1977-091X (electronic edition)
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