The judgment reads as something of a ‘whitewash’, supporting the Commission on every ground, write Paul Davison and Helen Buchanan (Freshfields Bruckhaus Deringer).
On 2 April 2019 with Brexit looming the EU Commission controversially published Decision SA.44896 (the Decision) concluding that aspects of the UK’s CFC rules constituted unlawful state aid. The Commission ordered the UK to recover tens of millions of pounds of alleged aid from affected UK groups which had claimed the benefit of the CFC group financing exemption in TIOPA 2010 Part 9A Chapter 9. The UK and many of the affected groups vehemently disagreed with the Commission’s reasoning and applied to the General Court (GC) of the Court of Justice of the European Union (CJEU) to annul the Decision. ITV was selected as a test case and applications made by all other affected groups were stayed behind ITV’s. The UK and ITV cases...
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The judgment reads as something of a ‘whitewash’, supporting the Commission on every ground, write Paul Davison and Helen Buchanan (Freshfields Bruckhaus Deringer).
On 2 April 2019 with Brexit looming the EU Commission controversially published Decision SA.44896 (the Decision) concluding that aspects of the UK’s CFC rules constituted unlawful state aid. The Commission ordered the UK to recover tens of millions of pounds of alleged aid from affected UK groups which had claimed the benefit of the CFC group financing exemption in TIOPA 2010 Part 9A Chapter 9. The UK and many of the affected groups vehemently disagreed with the Commission’s reasoning and applied to the General Court (GC) of the Court of Justice of the European Union (CJEU) to annul the Decision. ITV was selected as a test case and applications made by all other affected groups were stayed behind ITV’s. The UK and ITV cases...
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