Loyens & Loeff | EU Tax Alert Highlights 2025

In the course of 2025, there have been several important developments in the field of EU tax law. This annual edition of the EU Tax Alert provides an overview of those developments in the areas of Direct Taxation, State Aid, VAT, Customs Duties, Excises and other Indirect Taxes.

Highlights of this annual edition include the following developments:

• France’s Constitutional Court upholds French Digital Service Tax (DST)
• Belgian Constitutional Court refers case to the CJ on the compatibility of the UTPR with EU Law
• CJ judgment on the application of the GAAR under the PSD to national participation exemptions (Nordcurrent group, C-228/24)
• CJ judgment on the circumstances in which tax exemptions may be prohibited by EU law (Prezydent Miasta Mielca, C-453/23)
• CJ judgment on the compatibility of Polish tax exemption applicable only to externally managed collective investment funds with the free movement of capital (F S.A. v Dyrektor Krajowej Informacji, Case C 18/23)
• Member States raise concerns about implementing Pillar 2 Side-by-Side System without amending the EU Directive
• EU Commission budget proposal and Corporate Contribution (CORE) as New Own Resource: Discussions in the Council show pushback from Member States
• EU Council adopts DAC9 to facilitate the filing and exchange of Pillar Two-related information in the EU
• CJ judgment regarding VAT treatment of transfer pricing adjustments for intra-group services (Arcomet, C-726/23)
• VAT in the Digital Age adopted
• Regulation simplifying CBAM adopted

Read the full EU Tax alert Highlights 2025 here.

Authors:

• Juan Manuel Vázquez, Senior Associate, LOYENS & LOEFF
• Daan Both, Associate, LOYENS & LOEFF
• Kevin Duin, Junior Associate, LOYENS & LOEFF
• Oumaima Tarifit, Junior Associate, LOYENS & LOEFF
• Gino Sparidis, Senior Associate, LOYENS & LOEFF
• Bram Middelburg, Associate, LOYENS & LOEFF
• Emma van Doornik, Counsel, LOYENS & LOEFF
• Bruce van Schaik, Senior Associate, LOYENS & LOEFF
• Gijs Groenewoud, Junior Associate, LOYENS & LOEFF

Compliments of Loyens and Loeff- A member of the EACCNY