On 3 October 2012, the Court of First Instance Bruges (Rechtbank van Eerste Aanleg Brugge) gave its decision in X NV v. the Belgian Tax Administration on the treatment of the non-deductible part of the foreign dividend deduction. Details of the case are summarized below. (a) Facts. The Taxpayer was a Belgian company which could not fully use the 95% foreign dividend deduction. Therefore, the Taxpayer claimed a carry-forward of the non-used part of the deduction and included it in the losses to be carried forward. Based on a 2009 Circular, the tax administration refused to include the unused part of the...