UK: Repayment of State aid and interest following CJEU annulment of European Commission decision

Regulations providing for repayment will become effective December 31, 2024

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December 19, 2024

Following the September 19, 2024, judgment of the Court of Justice of the European Union (CJEU) annulling the decision of the European Commission (EC) that certain UK rules on the taxation of controlled foreign companies (CFCs) constitute unlawful State aid (read TaxNewsFlash), HM Treasury issued The Controlled Foreign Companies (Reversal of State Aid Recovery) Regulations 2024 to provide for the repayment of the “unlawful State aid” and interest paid by affected companies. 

Under the regulations, which will become effective December 31, 2024, the repayment will occur by means of HMRC giving “reversal notices” to any company affected by Schedule 7ZA of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) and cancelling any interest charging notices given to any affected company as soon as reasonably practicable.

Read a December 2024 report prepared by the KPMG member firm in the United Kingdom

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