According to the Commission’s final decision in State aid scheme UK CFC Group Financing Exemption, the group financing exemption included in the UK CFC rules does not constitute illegal State aid in cases where financing income relates to UK-connected capital. However, the group financing income is not justified and constitutes illegal State aid when the financing income derives from UK activities. This paper provides the background, the facts and the Commission’s findings, and concludes with comments on the case.
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