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ARTICLE · 20 MARCH 2026

EU Tax Alert 214

Loyens & Loeff
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The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarised the highlights of this edition below.

European UnionTax
Juan Manuel Vázquez
Juan Manuel Vázquez
Daan Both
Daan Both
Kevin Duin
Kevin Duin
Gino Sparidis
Gino Sparidis
Bram Middelburg
Bram Middelburg
Oumaima Tarifit
Oumaima Tarifit
Bruce Van Schaik
Bruce Van Schaik
Gijs Groenewoud
Gijs Groenewoud

The new edition of the EU Tax Alert is available. With this publication we would like to keep you informed about the latest developments on EU tax law. We have summarised the highlights of this edition below.

CJ judgment on whether Belgium correctly implemented the CFC rules under the ATAD

(Commission v Belgium, C-524/23)

On 26 February 2026, the Court of Justice (CJ), delivered its judgment in the case Commission v Belgium (Case C‑524/23). The case concerns the alleged failure by the Kingdom of Belgium to transpose Article 8(7) of Directive (EU) 2016/1164 (the Anti-Tax Avoidance Directive, ATAD), which requires Member States to allow a deduction for taxes paid by a controlled foreign company (CFC) abroad, when its income is attributed to the domestic taxpayer. The central legal issue addressed by the CJ in this case is whether the provision mentioned above must be implemented when a Member State opts for the CFC regime set out in Article 7(2)(b) ATAD, which

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