In a major coordinated enforcement push aimed at ensuring compliance with European Union law, the European Commission announced the launch of three distinct infringement procedures targeting the economic core of the bloc: Germany (case INFR(2026)2089), France (case INFR(2026)2087), and Italy (case INFR(2026)2088). The opening salvos of these legal disputes were delivered via letters of formal notice—the official first step in the EU’s strict enforcement protocol—focusing heavily on national discrepancies in cross-border corporate tax treatments.

The core of the executive’s legal challenge lies in how national tax authorities in Berlin, Paris, and Rome handle the incoming dividends received by domestic parent companies from their corporate subsidiaries established in other EU Member States. According to comprehensive technical audits conducted by Brussels, the domestic tax laws of these three nations lead to an unlawful, indirect multiplication of tax burdens on these specific financial flows. The Commission asserts that this practice vastly exceeds the tightly restricted exemptions permitted under primary European corporate tax directives.

The underlying legal foundation of the Commission's entire case is the Parent-Subsidiary Directive (originally Council Directive 90/435/EEC, later recast as Directive 2011/96/EU). This milestone directive was specifically drafted with a clear i...