Clifford Chance

£1 billion+ state aid to be recovered from UK corporates with finance subsidiaries - How should businesses react?

2 April 2019

The Commission has now issued its final decision in its State aid investigation into the Group Finance Exemptions from the UK's controlled foreign companies (CFC) rules, concluding that the exemptions constitute unlawful State aid.

UK parented groups which benefitted now face significant retrospective tax bills dating back to 2013 and should take immediate steps to protect their position. Groups with finance companies in EU/EEA states will have a stronger basis to resist enforcement against them, based on EU law.

Download PDF