Judgment_paragraph 71 · Sofina SA and Others v Ministre de l'Action et des Comptes publics (C-575/17)

71In the first place, the rules on the deferral of taxation in the event of losses constitute, inherently, a derogation to the principle of taxation during the tax year in which the dividends are distributed, so that those rules are not intended to apply to the majority of companies which receive dividends.