The EU Non-Performing Loans (NPL) Directive (2021/2167) aims to promote a more competitive and liquid market for NPLs by removing regulatory barriers for purchasing NPLs by non-banking investors. At the same time, banking taxes continue to exist, which could potentially result in tax advantages for investors who are not classified as financial institutions and therefore are not subject to banking tax. The question raised in this note is whether that advantage may be considered as prohibited State aid. The note highlights the major elements that should be investigated in order to provide a clear answer.