After a run of less successful cases on fiscal state aid the General Court’s judgment of 8 June 2022 (T-363/19 and T-456/19) will have been particularly welcomed by the Commission and may well encourage it to pursue other state aid investigations in particular in relation to aid schemes with renewed vigour. But there is much to criticise in the judgment which is a significant blow to the UK and to the affected groups who have benefited from the offending legislation.
The UK’s finance company exemption from the controlled foreign company (CFC) rules (in TIOPA 2010 Part 9A Chapter 9) was intended to provide certainty for taxpayers and HMRC of...
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After a run of less successful cases on fiscal state aid the General Court’s judgment of 8 June 2022 (T-363/19 and T-456/19) will have been particularly welcomed by the Commission and may well encourage it to pursue other state aid investigations in particular in relation to aid schemes with renewed vigour. But there is much to criticise in the judgment which is a significant blow to the UK and to the affected groups who have benefited from the offending legislation.
The UK’s finance company exemption from the controlled foreign company (CFC) rules (in TIOPA 2010 Part 9A Chapter 9) was intended to provide certainty for taxpayers and HMRC of...
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