The Commission has determined that Gibraltar’s tax exemption regime for passive interest and royalties between 2011 and 2013 selectively favoured certain multinational companies in breach of State aid rules (article 107 of the TFEU). Furthermore, the Commission found that five tax rulings issued by Gibraltar during the same period constituted State aid. This paper provides the background, the facts and the line of reasoning, and it concludes with the implications of the Commission’s decision.
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