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)

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).