Paul Davison and Sam Withnall (Freshfields Bruckhaus Deringer) report on the progress of the state aid recovery following the Commission’s final decision in its investigation last year.
Last April the European Commission announced its final decision in its state aid investigation into the UK’s controlled foreign company (CFC) rules concluding that the finance company exemption/partial exemption constituted unlawful state aid but only to the extent that it protected against the ‘UK SPFs’ sub-gateway (see Paul’s article ‘The state aid ruling on UK’s CFC regime: an EU compromise’ Tax Journal 12 April 2019).At that time the Commission ordered the UK to recover the aid from taxpayer beneficiaries setting a four-month deadline. Now almost a year on the UK is yet to recover any alleged aid from most beneficiaries. What has been happening in the meantime?
EU proceedings
The intervening period...
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Paul Davison and Sam Withnall (Freshfields Bruckhaus Deringer) report on the progress of the state aid recovery following the Commission’s final decision in its investigation last year.
Last April the European Commission announced its final decision in its state aid investigation into the UK’s controlled foreign company (CFC) rules concluding that the finance company exemption/partial exemption constituted unlawful state aid but only to the extent that it protected against the ‘UK SPFs’ sub-gateway (see Paul’s article ‘The state aid ruling on UK’s CFC regime: an EU compromise’ Tax Journal 12 April 2019).At that time the Commission ordered the UK to recover the aid from taxpayer beneficiaries setting a four-month deadline. Now almost a year on the UK is yet to recover any alleged aid from most beneficiaries. What has been happening in the meantime?
EU proceedings
The intervening period...
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