Different tax treatment of full and partial repayment of subscribed capital not discriminatory

On 20 June 2007, The Belgian Constitutional Court decided on a preliminary ruling requested by the Court of Appeal Ghent on 20 October 2006 concerning the taxability of lump-sum payments received from a partial repayment of a company's subscribed capital.
(a) Facts. NV Hebalo in 1995 reduced its subscribed capital and paid a lump sum to its shareholders pursuant t…
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