Judgment_paragraph 36 · Brussels Securities SA v État belge (C-389/18)

36In order to ensure the neutrality, from the tax point of view, of the distribution of profits by a subsidiary established in one Member State to its parent company established in another Member State, Directive 90/435 aims to avoid, in particular by the rule laid down in the first indent of Article 4(1) in economic terms, double taxation of profits, in other words, to avoid taxation of distributed profits, first, in the hands of the subsidiary and, then, in the hands of the parent company (see, to that effect, judgments of 3 April 2008, Banque Fédérative du Crédit Mutuel, C‑27/07, EU:C:2008:195, paragraphs 24, 25 and 27, and of 12 February 2009, Cobelfret, C‑138/07, EU:C:2009:82, paragraphs 29 and 30).

Brussels Securities SA v État belge (C-389/18)

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