Circular on participation exemption issued (25/06/2009) |
The Belgian government agreed on 15 May 2009 to comply with the European Court of Justice (ECJ) decision in the Cobelfret case (Cobelfret v Belgium (C-138/07)), in which the Court upheld that the Belgian dividends received deduction (DRD) regime is incompatible with article 4(1) of the EC Parent-Subsidiary Directive because it fails to effectively refrain from taxing dividends in some situations. The government has now issued an administrative circular setting out its position on the effects of the Cobelfret decision.

Circular on participation exemption issued (25/06/2009)