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State aid ruling on the UK’s CFC regime: an update on recovery

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The Commission’s final decision in its state aid investigation into the UK’s CFC rules obliged the UK promptly to recover the alleged aid from beneficiaries. Quantifying the amounts involved is difficult, and so progress has been slow. HMRC recently issued a statement clarifying several aspects of their approach to recovery, including how they will apply the ‘UK SPFs’ sub-gateway to intra-group lending.
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