Tax rulings: The General Court of the European Union confirms the decision of the European Commission according to which the exemptions granted to certain multinationals derogated from the United Kingdom’s rules applicable to controlled foreign companies in that they introduced differential treatment between taxable companies in a comparable situation, in the light of the objective of the said rules (ITV)

*This article is an automatic translation of the original article, provided here for your convenience. Read the original article. In its decision of April 2, 2019, the Commission had concluded that the exemption scheme on group financing the exemptions provided for in Chapter 9 of Part 9 A of the No. 9 of Part 9 A of the Taxation (International and Other Provisions) Provisions) Act 2010 [hereinafter "TIOPA"], constituted State aid within the State aid within the meaning of Article 107(1) TFEU, insofar as it applied to non-commercial financial benefits from eligible loans, which were covered by Article 371 of the falling under section 371EB (activities in the United Kingdom) of the said TIOPA. Factual and legal context The contested decision considered it to be an aid scheme aid

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Authors

  • Sheppard, Mullin, Richter & Hampton (Brussels)
  • Sheppard, Mullin, Richter & Hampton (Brussels)

Quotation

Jacques Derenne, Dimitris Vallindas, Tax rulings: The General Court of the European Union confirms the decision of the European Commission according to which the exemptions granted to certain multinationals derogated from the United Kingdom’s rules applicable to controlled foreign companies in that they introduced differential treatment between taxable companies in a comparable situation, in the light of the objective of the said rules (ITV), 8 June 2022, Concurrences N° 3-2022, Art. N° 108232, pp. 155-158

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