Nouvelles règles en matière de revenus définitivement taxés
| Auteur | Martin Van Beirs |
En 1990, l'Union européenne a adopté la directive fiscale "mère-fille", visant à supprimer toute double imposition des dividendes distribués entre une société filiale établie dans un Etat membre, et sa société mère établie dans un autre Etat membre. La filiale ayant en principe subi l'impôt sur le bénéfice qu'elle distribue à sa mère, il convient que ce même bénéfice ne soit pas à nouveau imposé lors de cette distribution.
A cette fin, la Directive mère-fille édicte deux règles essentielles : l'Etat de la société filiale qui distribue le dividende doit exonérer celui-ci de toute retenue à la source, d'une part, et l'Etat de la société mère qui reçoit le dividende doit prévoir un système d'exemption ou d'imputation...
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