The CJEU upheld a prior ruling dismissing Fugro NV’s challenge to the EU Global Minimum Tax Directive, finding the Dutch multinational lacked standing to request its partial annulment.
The Court of Justice of the European Union (CJEU) rejected an appeal filed by Dutch multinational enterprise group Fugro NV on 30 October 2025, upholding the EU General Court’s earlier decision to dismiss the company’s challenge to the EU Global Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022).
The core issue is whether Fugro, a Dutch-based multinational enterprise benefiting from a national “tonnage tax” scheme, had locus standi (the right to bring proceedings) to seek the partial annulment of Directive (EU) 2022/2523, which concerns a global minimum level of taxation for large enterprise groups.
The Court addressed Fugro’s argument that it was individually concerned by the directive because it was part of a limited class of operators whose acquired rights were allegedly affected. Ultimately, the Court dismissed the appeal, ruling that the General Court correctly found that Fugro was not individually concerned by the directive and therefore lacked standing.
According to the Order of the General Court from 15 December 2023, concerning Case T-143/23, in which the applicant, Fugro NV, sought the partial annulment of a European Union directive on global minimum taxation for large-scale enterprise groups.
Fugro NV has been benefiting from the Dutch tonnage tax scheme, argued against the limited scope of the directive’s exclusion for international shipping income, claiming it would negate the tax benefits they had acquired.
The Council of the European Union, the defendant, raised a plea of inadmissibility, arguing that Fugro NV was not individually concerned by the directive, a legislative act of general application.
Ultimately, the General Court upheld the Council’s plea, concluding that Fugro NV lacked standing because the directive did not uniquely identify it. Thus, the action was dismissed as inadmissible.
