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Belgian Court of Appeal issues decisions on tax abuse – application of the CJEU Danish cases

|Tax Alerts, Legislation & Policy, Na ...|Belgium, European Union
Belgium, European Union

In two recent decisions, the Belgian Court of Appeal of Ghent ruled on the tax treatment of a dividend distribution by a Belgian company to its Luxembourg holding vehicle. In both cases, the tax exemptions applied at source were denied on the basis of general anti-abuse principles.

The cases are landmark cases as they provide a first insight on how the general anti-abuse provision (GAAR) may be app…

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