In Groupe Steria v Ministère des Finances et des Comptes publics (C-386/14) (2 September 2015) the CJEU found that the unequal tax treatment of dividends received by the parent company of a tax integrated group depending on whether the subsidiaries were established in the same member state as the parent company was contrary to EU law.
Groupe Steria was the parent company of a tax integrated group. Steria a member of that group had holdings of more than 95% in subsidiaries established in France and in other member states. In accordance with French law the dividends received by Steria from the subsidiaries established in other member states were deducted from its net total profits except for a proportion of costs and expenses – this exception was fixed at 5% of the net amount of the dividends received and represented the costs and expenses borne...
