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Tax rulings

A dedicated Task Force on Tax Planning Practices was set up in summer 2013 to follow up on public allegations of favourable tax treatment of certain companies (in particular in the form of tax rulings). The Commission extended this information inquiry to all Member States in December 2014, including a list of tax rulings issued in recent years, on the basis of which individual tax rulings have been requested.

The list of final decisions adopted since 2014 concerning tax planning practices and the list of formal ongoing investigations is presented below.

Final Decisions

Member State

Title

Date of decision

Link to final decision

Press release

Case no./ link to case

UK

UK tax scheme for multinationals (Controlled Foreign Company rules)

02.04.2019

Letter to Member State en

IP/19/1948

SA.44896

Luxembourg

Alleged aid to McDonald's

19.09.2018

Letter to the Member State - working language en

IP/18/5831

SA.38945

Luxembourg

State aid implemented by Luxembourg in favour of ENGIE

20.06.2018

Letter to the Member State - working language en

IP/18/4228

SA.44888

Luxembourg

State aid granted by Luxembourg to Amazon

04.10.2017

Letter to the Member State - working languageen

IP/17/3701

SA.38944

Ireland

State aid implemented by Ireland to Apple

30.08.2016

Letter to the Member State - working language en

IP/16/2923

SA.38373

Belgium

Excess Profit exemption in Belgium – Art. 185§2 b) CIR92

11.01.2016

Letter to the Member State - working language en

IP/16/42

SA.37667

The Netherlands

State aid implemented by the Netherlands to Starbucks

21.10.2015

Letter to the Member State - working language en

IP/15/5880

SA.38374

Luxembourg

State aid which Luxembourg granted to Fiat

21.10.2015

Letter to the Member State - working language en

IP/15/5880

SA.38375

Open formal investigations

Member State

Title

Date of decision

Link to opening decision

Press release

Case no./ link to case

The Netherlands

Possible State aid in favour of Inter IKEA

18.12.2017

Letter to the Member State - working language en

IP/17/5343

SA.46470

The Netherlands

Alleged aid to Nike

10.01.2019

Letter to the Member State - working language en

IP/19/322

SA.51284

Luxembourg

Alleged aid to Huhtamäki

07.03.2019

Letter to the Member State - working language en

IP/19/1591

SA. 50400

Belgium

Excess Profit Exemption

16.09.2019

N/A

IP/19/5578

SA.53964 to SA.54002

Previous decisions

The Commission has in the past adopted numerous decisions on tax planning practices, which provide precedents in the ongoing investigations.

  • Aid C 55/01 - Aland Island Captive Insurance Companies, Finland (Harmful Measure: C 008) - OJ L 329/2002
  • Aid C 48/01 - Vizcaya Coordination Centres, Spain (Harmful Measure: A 004) - OJ L 31/2003
  • Aid C 47/01 - Control and Coordination Centres, Germany (Harmful Measure: AAM 019) - OJ L 177/2003
  • Aid C 50/01 - Finance Companies, Luxembourg (Harmful Measure: B 003) - OJ L 153/2003
  • Aid C 49/01 - Coordination Centres, Luxembourg (Harmful Measure: A 007) - OJ L 170/2003
  • Aid C 16/02 - Trieste Financial Services and Insurance Centre, Italy (Harmful Measure: B 002) - OJ L 91/2003
  • C 46/01 - Central Corporate Treasury Companies, France (Measure not considered harmful by the Group) - OJ L 330/2003
  • C 51/01 - International Financing Activities, The Netherlands (Harmful Measure: B 004) - OJ L 180/2003
  • Aid C 15/02 - Coordination Centres, Belgium (Harmful Measure: A 001) - OJ L 282/2003
  • Aid C 54/01 - Companies with Foreign Income, Ireland (Harmful Measure: E 007) - OJ L 204/2003
  • Aid C 45/01 - Headquarters and Logistic Centres, France (Harmful Measure: A 006) - OJ L 23/2004
  • Aid C 53/01 - Gibraltar Qualifying Companies, UK (Harmful Measure: B 013) - OJ L 29/2005
  • Aid C 30/02 - Tax Ruling for US Foreign Sales Corporations, Belgium (Harmful Measure: Z 001) - OJ L 23/2004
  • Aid C 66/02 - Gibraltar Corporate Tax Reform, UK (Measure not examined by the Group but replacing the Exempt and Qualifying Companies schemes) - OJ L 85/2005
  • Aid C 3/06 - Exempt Holdings and Billionaire Holdings, Luxembourg (Harmful Measure: A 013) - OJ L 366/2006

Guidance

Related court judgements

Related information

The Commission's work in the area of tax rulings was also closely followed by the European Parliament's Special Committee on Tax Rulings and Measures Similar in Nature or Effect ("the TAXE Committee").

Special Committee on Tax Rulings and Measures Similar in Nature or Effect (TAXE 1) report