European Court of Justice Issues Advocate General Opinions on Belgian Excess Profit Tax Ruling Regime

The European Court of Justice (ECJ) March 26 issued Advocate General opinions for Case Nos. C 734/23 P, C 735/23 P, C 736/23 P, C 737/23 P to C 742/23 P, C 752/23 P, C 754/23 P, C 755/23 P, C 756/23 P, C 757/23 P, and C 758/23 P, on the Belgian excess profit tax ruling regime. The taxpayers, Belgian multinational group companies, received excess profit tax rulings between 2004 and 2014 under the Belgian Income Tax Code that reduced taxable profits by excluding excess profits from group synergies. The European Commission (EC) found that the excess profit exemption ...