European Union Gazettes ECJ Judgment on Global Minimum Taxation, Exclusion of International Shipping Income

The European Union Official Gazette Dec. 22 published the European Court of Justice (ECJ) judgment for Case No. C-146/24 P, on global minimum taxation for multinational enterprise (MNE) groups and the exclusion of international shipping income. The taxpayer, a Netherlands-based MNE subject to the Dutch tonnage tax regime, sought annulment of EU Directive 2022/2523, arguing that its exclusion of international shipping income failed to protect companies under the regime. The General Court dismissed the action, holding that the directive applied generally and didn’t individually concern the taxpayer or a closed class of operators. On appeal, the ECJ upheld the General ...