Court of First Instance Bruges decides that non-deductible part of the foreign dividend deduction can be included in loss carry-forward
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 divid…
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