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On 20 September 2023, the General Court of the European Union (GCEU) ruled for the second time in the case of the Belgian Excess Profits Ruling (Belgian EPR) (Judgment of the General Court, 20 September 2023, in case T-131/16). Contrary to its first judgment in 2019 on EPR, it now confirmed the decision of the European Commission (EC) of 11 January 2016 that the EPR constituted an unlawful tax scheme and infringed the EU State aid rules.

The CGEU judgment is open for appeal before the ECJ. It should however be limited to points of law. It is too early to comment on the contemplated course of action by the Belgian Government or the concerned multinational groups. Whether they will appeal the judgment on points of law is not yet known at this point in time.

Read more in this PwC EU Direct Tax Group newsalert.