42In that regard, it should be borne in mind that, in the judgment of 19 December 2019, Brussels Securities (C‑389/18, EU:C:2019:1132), which concerned the order in which deductible income was deducted from taxable profits under Belgian tax law, in particular DTI surpluses as compared with other income for which the carry-forward of the tax deduction was limited in time, the Court carried out a comparison of the situation at issue in that case, in which the parent company, at the time of the tax deduction, had to comply with the order of priority for deducting DTI surpluses as against another tax deduction, with the situation that would have prevailed if the Kingdom of Belgium had applied an exemption system which outright excluded dividends from the basis of assessment.
Source: EUR-Lex, © European Union, 1998-2026. Reuse authorised under Decision 2011/833/EU.