Advocate General Kokott’s Opinion in NEO Group (Case C-203/25): Key Clarifications on the Anti-Abuse Rule under the EU Parent-Subsidiary Directive

In this note, the author presents the most recent dividend anti-abuse case before the Court of Justice of the European Union (Neo Group (C-203/25)), including its facts, the position of the parties before the national court and an analysis of the recently published Opinion of Advocate General Kokott. This case is expected to further develop the conditions for the application of the anti-abuse rule established by the EU Parent-Subsidiary Directive (2011/96), especially in cases where the recipient of the dividends, in contrast to the situation in the Danish Cases (C-116/16 and C-117/16), is not a conduit company and is a beneficial owner of the dividends.