In its recent Nordcurrent Group UAB (C-228/24) judgment, the CJEU revisited the anti-abuse provisions of the Parent-Subsidiary Directive (2011/96/EU), building on the well-known Danish Cases (C-116-117/16). The Court sharpened the criteria for when a corporate structure is considered non-genuine, and clarified what qualifies as a tax advantage contrary to the Directive’s purpose. In this case, however, it found no abuse of the Directive’s exemption regime. A long-awaited and important development for corporations navigating EU substance rules and anti-abuse frameworks.

You may read more in our firm’s Knowledge Portal: https://knowledgeportal.karatza-partners.gr/observations-on-cjeu-case-c-228-24-judgment-of-3-april-2025-new-interpretative-tools-for-the-application-of-the-anti-abuse-rule-under-the-parent-subsidiary-directive-2011-96-eu/

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