Search results - Concurrences

15 Apr 2021 R

Economic unit: Advocate General Pitruzzella proposes to extend the liability of the parent company, perpetrator of anti-competitive practices, to its daughter, with which it constitutes an economic unit, in order to allow victims of competitive damage to act directly against the subsidiary (Sumal / Mercedes Benz Trucks España)

Alain Ronzano • N° 2-2021

On 15 April 2021, Advocate General Giovanni Pitruzzella delivered his Opinion in Case C-882/19 (Sumal, S.L.)which follows a reference for a preliminary ruling from the Barcelona Court of Appeal. The present Opinion - which should make some noise - is undoubtedly part of the movement to make it (...)

15 Apr 2021 R

Corporate group: The Court of Justice of the European Union confirms that the application of the presumption of the effective exercise of decisive influence by the parent company over its subsidiary does not violate the principle of legal certainty, the principle of legality of penalties or the principle of the presumption of innocence (Italmobiliare)

Alain Ronzano • N° 2-2021

On 15 April 2021, the Court of Justice of the European Union delivered a judgment in case C-694/19 (Italmobiliare and Others v. European Commission). By the terms of the present judgment, the Court dismisses in its entirety the appeal brought by Italmobiliare, the parent company of a group, (...)

13 Apr 2021 C

Antitrust in the Financial Sector #2 Current International Issues in the Financial Sector

Dennis Davis, Maria Velentza, Graciela Miralles Murciego, Vivek Mani, Ademir Antonio Pereira Junior, Oliver Latham, Linda Cenedella, Jon R. Roellke

2nd webinar of the 5th « Antitrust in Financial Sector » Conference organised by Concurrences and Morgan Lewis in partnership with Advocacia José Del Chiaro, Charles River Associates and Cornerstone Research, with Linda Cenedella (Partner, Morgan Lewis), Dennis Davis (Former President, Competition (...)

15 Jan 2021 B

The Indonesian Competition Authority imposes its first predatory pricing fine against a multinational cement manufacturer (CKSC)

Chalid Heyder, Dyah Paramita • January 2021

In a release, Komisi Pengawas Persaingan Usaha (KPPU) – the Indonesian Competition Authority, published its first Article 20 (Predatory Pricing) decision. The KPPU Decision No. 03/KPPU-L/2020 was issued on a virtual hearing on 15 January 2021, whereby KPPU found that PT Conch South Kalimantan (...)

3 Dec 2020 R

Existing aid: Advocate General Kokott, considering that the European Commission has sufficiently demonstrated the existence of an aid scheme in relation to the Belgian authorities’ practice of negative profit adjustment for companies belonging to a multinational group, calls on the Court of Justice of the European Union to annul the judgment of the General Court of the European Union and refer the case back to it (Magnetrol International)

Alain Ronzano • N° 1-2021

On December 3, 2020, General Counsel Juliane Kokott presented her conclusions. in Case C-337/19 (European Commission v Kingdom of Belgium and Magnetrol International). It calls on the Court of Justice of the European Union to uphold the Commission’s appeal and, consequently, to annul (...)

26 Nov 2020 B

The German Competition Authority clears the business-to-consumer side of a Phase II merger of furniture stores, subject to conditions and subject to clearance of the business-to-business side of the merger by the EU Commission (XXXLutz / Tessner group)

German Competition Authority • November 2020

Bundeskartellamt clears merger of XXXLutz and the Tessner group (Roller, tejo’s, Schulenburg) only subject to conditions* Following an in-depth examination the Bundeskartellamt has cleared the planned acquisition by Mann Mobilia Beteiligungs GmbH, based in Würzburg (part of the Austrian XXXLutz (...)

25 Nov 2020 R

Bid rigging: The French Competition Authority rules out the application of competition rules to concerted responses to calls for tenders made by companies in the same group (Ovimpex group / Dhumeaux / Mondial Viande Service / Vianov)

Alain Ronzano • N° 1-2021

On 25 November 2020, the Competition Authority issued a decision to dismiss the case under No 20-D-19. about practices implemented in connection with calls for tenders launched by France AgriMer for the supply of food products to associations responsible for their distribution to the most (...)

25 Nov 2020 B

The French Competition Authority amends its decision-making practice following a judgment of the EU Court of Justice on responses to calls for tenders by subsidiaries of the same group (Ovimpex group / Dhumeaux / Mondial Viande Service / Vianov)

French Competition Authority • November 2020

Responses to calls for tenders by subsidiaries of the same group: the Autorité amends its decision-making practice following a judgement of the CJEU* Following a judgement of the CJEU clarifying European case-law, the Autorité de la concurrence amends its decision-making practice, which until (...)

25 Nov 2020 B

The French Competition Authority announces an amendment on its decision-making practice concerning responses to calls for tenders by subsidiaries of the same group and stops considering it unlawful (Ovimpex / Dhumeaux / Mondial Viande Service / Vianov)

Adrien Giraud, Pierre Bichet • November 2020

French Competition Authority amends its decision-making practice in relation to responses to calls for tenders by subsidiaries of the same group* On 25 November 2020, the French Competition Authority (FCA) announced that it was amending its decision-making practice regarding responses to calls (...)

25 Nov 2020 B

The French Competition Authority amends its decision-making practice in the field of public procurement to comply with the recent case law of the EU Court of Justice, making the administrative courts to be the only regulators thereof (Ovimpex group / Dhumeaux / Mondial Viande Service / Vianov)

Paul Blin, Victor Chaptal • November 2020

Introduction On 25 November 2020, the French Competition Authority (hereafter, the “FCA”) amended its decision-making practice in the field of public procurement (FCA, Decision 20-D-19 of 25 November 2020), to comply with the recent judgement “Ecoservice Projektai” of the European Court of Justice (...)

20 Nov 2020 B

The Polish Competition Authority charges the supermarket group’s buyer company with abuse of contractual advantage against its suppliers (SCA PR Polska)

Polish Competition Authority • November 2020

Contractual advantage - proceedings of the President of UOKiK against SCA PR Polska (Intermarche Group)* President of UOKiK Tomasz Chróstny brought charges against SCA PR Polska, a company responsible in the capital group for purchases in the Intermarche chain. The company is likely to abuse (...)

29 Oct 2020 B

The Austrian Competition Authority files an application to fine four construction companies for price fixing, market division, and other anti-competitive conduct

Austrian Competition Authority • October 2020

AFCA files application to fine four construction companies for price fixing, market division and other anti-competitive conduct* The alleged infringements include price fixing, market divison and the exchange of competitively sensitive information. On 29 October 2020 the Austrian Federal (...)

28 Oct 2020 R

Fines: The Court of Justice of the European Union states that there is neither ’priority’ in the imposition of a fine, nor the benefit of order or discussion in the solidarity mechanism for the payment of the fine (Pirelli)

Alain Ronzano • N° 1-2021

On 28 October 2020, the Court of Justice of the European Union was again called upon to rule on one of the aspects of the proceedings relating to the electricity cable cartel, which had led the Commission, in a decision of 2 April 2014, to take a decision on the Commission’s decision on this (...)

15 Oct 2020 B

The Slovenian Competition Authority fines two corporate groups for failure to notify their merger (Agrokor / Ardeya Global)

Slovenian Competition Authority • October 2020

Slovenian Competition Protection Agency imposed fines on the breach of failure to notify the Agency of a concentration* Slovenian Competition Protection Agency has imposed a fine of EUR 53,900,000 on legal entity Agrokor d.d. and a fine of EUR 5,000 on legal person responsible for the failure (...)

6 Oct 2020 B

The EU Commission unconditionally clears a merger of two multinational groups both active in sports broadcasting and sale of advertising space (PPF / CME)

European Commission • October 2020

Mergers: Commission approves PPF’s acquisition of CME* The European Commission has approved unconditionally, under the EU Merger Regulation, the proposed acquisition of Central European Media Enterprises ("CME") by PPF Group NV ("PPF"). The Commission concluded the transaction would raise no (...)

23 Sep 2020 B

The French Competition Authority clears, subject to the conditions of divesting agencies and fleets, the acquisition in the sector for the rental of refrigerated and non-refrigerated industrial goods vehicles (Fraikin / Via Location)

French Competition Authority • September 2020

The Autorité de la concurrence clears, subject to the conditions of divesting agencies and fleets, the acquisition of the group Via Location by the group Fraikin* On 3 June 2020, the group Fraikin notified the Autorité of a plan to acquire full control of the company Via Location. The parties (...)

11 Sep 2020 B

The Romanian Competition Authority assesses the taking over of glass packing solutions provider by glass packing manufacturer for the food and beverage industry (Vetropack Austria Holding / Glass Container)

Romanian Competition Authority • September 2020

The Competition Council Assesses the Taking Over of Glass Container by Vetropack Austria Holding AG* The Competition Council assesses the transaction by which Vetropack Austria Holding AG intends to take over Glass Container Company S.A. and Glass Container Prim S.A., located in Republic of (...)

3 Sep 2020 B

The EU Court of Justice rules that the provision of Italian law preventing a media company from acquiring 28% of the capital in competitor as a measure of protecting pluralism of information is contrary to EU law (Vivendi / Mediaset)

European Court of Justice • September 2020

The provision of Italian law preventing Vivendi from acquiring 28% of the capital in Mediaset is contrary to EU law* That provision constitutes a prohibited impediment to the right of establishment as it is not appropriate for achieving the objective of protecting pluralism of information. (...)

2 Sep 2020 R

Fines: The French Supreme Court confirmes in the ’zinc case’ that the omission concerning the offender’s membership of a powerful group constituted a material error which the Court of Appeal was entitled to rectify (Umicore)

Alain Ronzano • N° 1-2021

In a judgment delivered on 2 September 2020The Commercial Chamber of the Court of Cassation, rejecting the appeals lodged by the Umicore group - the appeal lodged by the Chairman of the Authority, which was considered late, was declared inadmissible - not only confirms the judgment handed down (...)

26 Aug 2020 B

The Danish Competition Authority approves takeover of subsidiary and customer agreements as fulfillment of remedy required in merger of parent company in the natural gas market (OK / Ørsted Varmeservice)

Danish Competition Authority • August 2020

The Danish Competition Council has approved OK a.m.b.a.’s acquisition of natural gas customer agreements and Ørsted Varmeservice A/S* On 18 August 2020, the Danish Competition and Consumer Authority (hereinafter “DCCA”) received a complete notification of OK a.m.b.a.’s (hereinafter “OK”) (...)

25 Aug 2020 B

The Finnish Competition Authority opens in-depth investigation into the acquisition of agricultural business (Hankkija / SSO Rauta-Maatalous)

Finnish Competition Authority • August 2020

FCCA opens in-depth investigation into the acquisition between Hankkija and SSO Rauta-Maatalous* The Finnish Competition and Consumer Authority (FCCA) will further investigate the proposed acquisition of the agricultural business of SSO Rauta-Maatalous Oy by Hankkija Oy. Hankkija is company (...)

25 Aug 2020 B

The Romanian Competition Authority analyses a merger in the market for animal feed and related markets (Koninklijke DSM / Erber)

Romanian Competition Authority • August 2020

The Competition Council Analyses the Taking Over of Erber Aktiengesellschaft by Koninklijke DSM N.V.* The Competition Council analyses the transaction by which Koninklijke DSM N.V. and its subsidiary, DSM International Participations B.V., intends to take over Erber Aktiengesellschaft. (...)

4 Aug 2020 B

The Romanian Competition Authority opens investigation into the takeover of certain assets and shares between 2 competitors in the market for automotive components (Schlemmer Group / Delfingen Industry)

Romanian Competition Authority • August 2020

The Competition Council Analyses the Taking Over of Some Assets of Schlemmer Group by Delfingen Industry S.a* The Competition Council analyses the transaction by which Delfingen Industry S.A. intends to take over some assets and shares of Schlemmer Group. Delfingen Industry S.A., based in (...)

4 Aug 2020 B

The Japanese FTC clears managerial integration of 2 internet companies subject to conditions (Z Holdings / LINE)

Japanese Competition Authority • August 2020

The JFTC Reviewed the proposed managerial integration of Z Holdings Corporation and LINE Corporation* Receiving notifications regarding the proposed managerial integration between Z Holdings Corporation (JCN4010401039979) (hereinafter referred to as “ZHD”; a group of combined companies held by (...)

30 Jul 2020 B

The Portuguese Competition Authority issues a statement of objections to six waste management companies for non-competition agreement (Blueotter / EGEO)

Portuguese Competition Authority • July 2020

AdC issues Statement of Objections to six waste management companies for non-competition agreement* The AdC issued a Statement of Objections to six companies and six board members of the waste management groups Blueotter and EGEO with respect to a non-competition agreement, forbidden by (...)

15 Jul 2020 B

The EU General Court overturns the Commission’s biggest State aid recovery order worth over €13 billion in tax advantages (Apple)

Dimitrios Kyriazis • July 2020

Apple: One Case to Rule Them All* Some cases just have it all; the Apple case is one of them. First, size: at more than thirteen billion euros, the recovery order Ireland had to enforce dwarfed the previously biggest one (EDF, at around one billion euros). Second, international political (...)

15 Jul 2020 B

The EU General Court annuls the Commission’s decision that Ireland had granted illegal state aid of at least €13bn (Apple)

Aleksei Matiushenko, Nicole Robins • July 2020

In July 2020, the EU General Court annulled the European Commission’s decision that Ireland had granted illegal state aid of at least €13bn to Apple through two tax rulings. The General Court’s judgment in the Apple case was one of the most keenly awaited judgments in the area of state aid. What (...)

13 Jul 2020 B

The French Competition Authority clears without conditions the acquisition of sole control in producer of metal parts for luxury companies by major luxury group (J3L / Hermès Group)

French Competition Authority • July 2020

The Autorité de la concurrence clears the acquisition of sole control of J3L by the Hermès group* The Hermès group notified the Autorité de la concurrence of its plan to acquire sole control of the J3L company. After examining the effects of the transaction, the Autorité has cleared it without (...)

6 Jul 2020 B

The German Competition Authority clears merger of online dating platforms within the merger of their holding companies (Parship / Elite Partner / Lovoo)

German Competition Authority • July 2020

Parship and Elite Partner can acquire Lovoo* The Bundeskartellamt has cleared the planned acquisition of The Meet Group Inc., USA, by the ProSiebenSat.1 group. Since 2016 the portfolio of the ProSieben Sat.1 group has included the online dating platforms Parship and Elite Partner. The Meet (...)

6 Jul 2020 B

The German Competition Authority clears an acquisition of dating platforms on the basis that online dating market is characterised by dynamic growth, market entries and competition (Parship / Elite Partner / Lovoo)

Marcio da Silva Lima • July 2020

The ProSiebenSat.1 Group strengthens its Internet dating platform business with the acquisition of the US app developer Meet Group. Although the Federal Cartel Office (FCO) found, that the acquisition will lead to further concentration in the online dating sector, the FCO, however cleared the (...)

24 Jun 2020 B

The Danish Competition Authority approves an energy and fiber optic group’s acquisition of several companies from another energy group with services covering mostly separate geographic markets, subject to divestment of customers in a highly overlapping market (SEAS-NVE / Ørsted)

Danish Competition Authority • June 2020

The Danish Competition Council has approved SEAS-NVE A/S’ acquisition of several companies from Ørsted A/S subject to commitments* On 28 May 2020, the Danish Competition and Consumer Authority (hereinafter “DCCA”) received a complete notification of SEAS-NVE A/S’ (hereinafter “SEAS-NVE”) (...)

10 Jun 2020 B

The OECD holds a roundtable on conglomerate effects of mergers

OECD • June 2020

Conglomerate effects arise when a merger has an effect on competition, but the merging firms’ products are not in the same product market, nor are they inputs or outputs of one another. Mergers exhibiting conglomerate effects have taken on a new prominence in the digital era, as the largest (...)

9 Jun 2020 B

The EU Commission refers to the French Competition Authority a takeover case of 567 French-owned hard discount stores by one of Europe’s main hard discount groups as per request of the acquisition parties (Leader Price / Aldi)

French Competition Authority • June 2020

The European Commission refers to the Autorité de la concurrence the takeover transaction of 567 Leader Price stores by Aldi* A few months after Aldi announced the takeover of Leader Price stores, the parties concluded, in March, a promise to purchase for 567 Leader Price stores and 3 (...)

3 Apr 2020 B

The Danish Competition Authority requests a referral to the EU Commission for a proposed acquisition between two financial services companies on the basis that the merger might affect markets in other member states (Mastercard / Nets)

Morten Nissen, Frederik Haugsted • April 2020

The Danish Competition and Consumer Authority ("DCCA") has for the first time ever requested a referral of a merger to the European Commission under Article 22(1) of the EU Merger Regulation. The referral concerns the proposed acquisition by Mastercard/Europay U.K Limited of certain parts of (...)

1 Apr 2020 B

The US FTC sues to unwind a cigarette company’s $12.8 billion investment in its competitor in the market for closed-system e-cigarettes (Altria Group / JUUL Labs)

US Federal Trade Commission • April 2020

FTC Sues to Unwind Altria’s $12.8 Billion Investment in Competitor JUUL* Today, the Federal Trade Commission filed an administrative complaint alleging that Altria Group, Inc. and JUUL Labs, Inc. entered a series of agreements, including Altria’s acquisition of a 35% stake in JUUL, that (...)

11 Feb 2020 B

The US FTC starts examining acquisitions by 5 Big Tech companies from the 2010-2019 period that were not reported to the antitrust agencies under the Hart-Scott-Rodino Act (Alphabet / Amazon / Apple / Facebook / Microsoft - 6(b) Platform Study)

US Federal Trade Commission • February 2020

FTC to Examine Past Acquisitions by Large Technology Companies* Agency Issues 6(b) Orders to Alphabet Inc., Amazon.com, Inc., Apple Inc., Facebook, Inc., Google Inc., and Microsoft Corp. The Federal Trade Commission issued Special Orders to five large technology firms, requiring them to (...)

16 Oct 2019 R

Sudden break: The French Supreme Court considers that a group of companies cannot be party to an established commercial relationship (Sabet Persepolis / Galeries Lafayette)

Frédéric Buy • N° 1-2020 • pp. 109-110

How does the law on abrupt breakups deal with corporate groups? The ruling handed down by the Court of Cassation on 16 October 2019 (CCC 2019, no. 199, obs. N. Mathey) provides an opportunity to take stock of a question that is certainly classic, but always delicate (see not. F. Buy, L’article (...)

1 Sep 2019 R

The DOJ’s guidance on evaluation of corporate compliance programs

Stephen T. Cheng • N° 3-2019

On April 30, 2019, the US Department of Justice released a new guidance on the evaluation of corporate compliance programs. The guidance is centered around three key questions: (1) Is the Compliance Program well designed?; (2) Is the Compliance Program effectively implemented?; and (3) Does the (...)

1 Sep 2019 B

The Chinese State Administration for Market Regulation issues three new sets of rules and regulations relating to monopoly agreements, abuse of dominant market positions and abuse of administrative power

Shelley Zhang, Till Steinvorth • September 2019

This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. September 1, 2019 may be seen as a new starting point for the enforcement of China’s antitrust and competition laws. On this date, three new sets of rules and (...)

24 Jun 2019 B

The Swiss Federal Supreme Court affirms a major ticket sale company’s sole legitimacy to submit a complaint against the Competition Commission’s prohibition of the merger between its wholly owned subsidiary and another company (Ticketcorner Holding / Tamedia)

Marcel Meinhardt • June 2019

In its decision of June 24, 2019, the Federal Supreme Court affirms Ticketcorner Holding AG’s sole legitimacy to lodge a complaint against ComCo’s prohibition of the merger between its wholly-owned subsidiary Ticketcorner AG and Starticket AG. The Federal Supreme Court thereby clarifies that (...)

20 Jun 2019 B

The Indian Competition Authority clears a minority shareholdings acquisition in the financial industry after the submission of the merger notification (Kedaara / Ajax)

Pallavi Shroff, John Handoll, Naval Satarawala Chopra, Shweta Shroff Chopra, Harman Singh Sandhu, Manika Brar, Aparna Mehra, Gauri Chhabra, Yaman Verma, Rohan Arora • June 2019

The CCI cleared the acquisition by Kedaara Capital Fund (Kedaara), a private equity fund, of an approximately 7.98% stake in Ajax Engineering (Ajax), a manufacturer of concreting equipment. [1] Since there were no horizontal overlaps or vertical relationships, the CCI concluded that the (...)

31 May 2019 C

The Global Antitrust Economics Conference

Luis Cabral, Lawrence J. White, Noah Joshua Phillips, Roger Noll, Andrew Zimbalist, Brad Humphreys, Rodney Fort, Michael D. Hausfeld, James A. Keyte, Gail Levine, Timothy J. Brennan, Gregory Rosston, Dennis W. Carlton, John D. Harkrider, Cristina Caffarra, Katja Seim, Paul Csiszar, David Gilo, George A. Rozanski, Ingrid Vandenborre, Jack E. Pace, Robert Willig, Samantha Knox, Martin d’Halluin, David A. Higbee, Boris Bershteyn, Harry First, Hal Varian

Annual Concurrences conference at NYU Stern School of Business with the support of Axinn, Bates White, CRA, Hausfeld, Qualcomm, Shearman & Sterling, Skadden, White & Case (Panel Sponsors) and MLex (Media Sponsor).

27 May 2019 B

The Spanish Supreme Court issues judgement on the principle of individual nature of fines by assessing a €42 million fine to the parent company of an energy group (Repsol)

Pedro Callol • May 2019

In 2015, the NMCC imposed two fines on Repsol S.A. (Repsol), the parent company of the energy group, amounting to €20 and €22.5 million for coordinating prices through exchanges of information with competitors and for fixing of fuel prices at service stations, respectively. Repsol appealed the (...)

15 May 2019 B

The Polish Competition Authority clears merger subject to the resulting corporate group’s accepting to sell two fuel stations (BP Europa / Arge Paliwa / Arge Nieruchomości)

Polish Competition Authority • May 2019

Conditional approval for concentration: BP - Arge* The Office of Competition and Consumer Protection (UOKiK) issued an approval for acquisition, by BP Europa, of control over Arge Paliwa and Arge Nieruchomości. The Transaction may become effective under the condition that the acquiring company (...)

7 May 2019 R

Sudden termination: The French Supreme Court decides that the commercial relationship must be understood as the contractual links existing between the companies, without taking into account the notion of parent and subsidiary companies (Rotosiam Batfim / Carrefour)

Jean-Louis Fourgoux • N° 3-2019 • p. 108

This case is quite revealing of the difficulty of including in the termination of commercial relations the notion of industrial relations within a group. In the first years of application of the text, the case law was fairly flexible with the victims and accepted that they could include in the (...)

1 May 2019 R

Joseph Stiglitz (Columbia University): Competition policy, the need for a more nuanced view

Joseph E. Stiglitz, Eleanor M. Fox • N° 2-2019 • pp. 16-17

Interview conducted by Eleanor Fox, Walter J. Derenberg Professor of Trade Regulation, NYU Law, New York. Professor Stiglitz, you have given a great deal of thought to competition policies in developing countries and you have been very important in helping many of them frame their policy (...)

12 Apr 2019 R

Admissibility: The General Court of the European Union rules that the appeal of a German airline is inadmissible due to the applicant’s lack of individual concern (Lufthansa)

Alain Ronzano • N° 3-2019

On 12 April 2019, the Court of First Instance of the European Union delivered a judgment in Case T-492/15 (Deutsche Lufthansa v Commission). Following the action brought by the German airline seeking annulment of the Commission’s decision of 1 October 2014In its decision, the Commission found (...)

2 Apr 2019 B

The EU Commission concludes that aspects of UK controlled foreign company rules constitute unlawful State aid

Kate Habershon, Neil McKnight, Leonidas Theodosiou • April 2019

This article has been nominated for the 2020 Antitrust Writing Awards. Click here to learn more about the Antitrust Writing Awards. The European Commission has published a summary of its findings in its state aid investigation into the U.K.’s controlled foreign company (CFC) finance company (...)

14 Feb 2019 B

The EU General Court annuls the Commission decision which classified Belgium’s "excess profit" tax scheme as State aid (Magnetrol International)

Markus Wellinger • February 2019

On 14 February 2019, the General Court (“GC”) issued a judgment annulling the decision of the European Commission (the “Commission”) concerning the Belgian “excess profit” tax rulings (Joined Cases T-131/16 and T-263/16, Belgium and Magnetrol International v. Commission). Under Belgian law, Belgian (...)

14 Feb 2019 B

The EU General Court annuls the Commission’s State aid decision regarding Belgian excess profits tax ruling system (Magnetrol International)

Mathieu Vancaillie, Koen Platteau • February 2019

In a Decision of 11 January 2016, the European Commission declared the Belgian excess profit scheme, pursuant to which Belgium granted advance tax rulings authorising Belgian entities which were part of multinational groups to exempt part of their profits from corporate income taxation, (...)

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