Germany - The German Restructuring Privilege (Section 8c(1a) of the Corporate Income Tax Act) and the EU State Aid Rules (Article 107(1) of the TFEU)
- C. Brodersen; N. Mückl
- European Taxation, 2014 (Volume 54), No 2/3
- 30 January 2014
The authors examine whether or not the German Restructuring Privilege qualifies as a selective measure in terms of article 107(1) of the TFEU, as was decided by the European Commission, in light of the recent ECJ decision in P Oy (Case C-6/12).