CJ rules that limitations to the Belgian notional interest deduction regarding exempt foreign permanent establishments are in line with the freedom of establishment (Argenta Spaarbank)
25/11/2019
On 17 October 2019, the CJ issued its judgment in case Argenta Spaarbank (C-459/18). The case deals with the calculation of the notional interest deduction (deduction for capital risk) in the case of a Belgian company that has a Netherlands permanent establishment the income of which is exempt under the double tax treaty signed between those countries. The CJ concluded that there is no actual difference between how the deduction applies to domestic and foreign permanent establishments.
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