General Court judgment on the Commission’s State aid decision on the UK CFC rules (United Kingdom and ITV plc v Commission, T-363/19 and T-456/19)
On 8 June 2022, the General Court delivered its judgment in the case United Kingdom and ITV plc v Commission (T-363/19 and T-456/19). In the case, the Court ruled that an exemption in the controlled foreign company (CFC) rules applicable in the United Kingdom (UK) until 31 December 2018 constitutes State aid.
EFTA court rules on whether a denial of an interest deduction under Norwegian legislation is contrary to the freedom of establishment (PRA Group Europe AS v the Norwegian Government, E-3/21)
On 1 June 2022, the EFTA Court published its decision in the case PRA Groupe Europe AS (E-3/21). The case concerns the issue of whether a denial of an interest deduction resulting from the combined application of the Norwegian limited interest deduction rules and group contribution rules is contrary to the freedom of establishment as provided in the Agreement on the European Economic Area (EEA).
CJ judgment on joint and several liability of indirect customs representative for VAT purposes (I. Srl, C 714/20)
On 12 May 2022, the CJ delivered its judgment in the case U.I. Srl (C-714/20) about the possibility for EU Member States to hold indirect customs representative jointly and severally liable for import VAT.
EU Commission proposes a debt-equity bias reduction allowance (DEBRA)
On 11 May, the EU Commission published a Directive proposal on the debt-equity bias reduction allowance (DEBRA). The proposed Directive entails both a notional deduction on growth in equity and an additional interest deduction limitation for corporate income tax (CIT) purposes.
No agreement on the proposed EU Pillar Two Directive during the French presidency
Due to Hungary’s reservation, the ECOFIN failed to reach a unanimous agreement on the proposed EU Directive implementing Pillar Two during the six months French presidency of the Council of the EU, which lasted from 1 January to 30 June 2022.