Belgian Participation Exemption Not in Compliance With EU Parent/Subsidiary Directive

April 21, 2009
The European Court of Justice recently held that the Belgian participation exemption regime is not in compliance with the EU Parent/Subsidiary Directive, given that the exemption only applies when the parent company has a taxable profit balance after deduction of other exempted profits. This update examines the impact of the ruling, including how Belgian corporate taxpayers can address the issue through administrative procedures.