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Update: EU State Aid investigation

Update: EU State Aid investigation

The latest insights and frequent updates on EU State Aid CFC Finco exemption investigation and its impact on affected taxpayers.


Partner, International Tax

KPMG in the UK


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On 26 October 2017, the European Commission (“EC”) announced an investigation into whether the 75% and 100% UK CFC Group Financing Exemptions (“Finco Exemptions”) breach EU state aid rules, within the meaning of Article 107(1) Treaty on the Functioning of the European Union (“TFEU”).

The EC has indicated a preliminary view that the Finco Exemptions amount to illegal state aid, as they confer a selective advantage on multinationals funding overseas group companies (vs. third parties and UK group companies).

The Eurpean Commission is expected to find that the Finco Exemptions amount to illegal state aid in line with its preliminary views and is expected to release its decision between August and November this year.

A negative decision by the EC means that the UK Government (“the UK”) will be required to take steps to recover the ‘illegal’ aid from recipients of the aid. 

Stay up to speed with our frequent updates on the latest developments of EC State Aid Finco Exemptions investigation. 

Read our CFC Finco state aid investigation webinar presentation to learn more.

Contact us to hear how we can help you navigate through your options in preparation for an anticipated EC decision and how we can support you with what you should consider and next steps. 


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KPMG International Cooperative (“KPMG International”) is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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