Can CFC rules be illegal subsidies?

In their article, Dr Shafi U. Khan Niazi and Professor Richard Krever examine a European Commission ruling that classified the U.K. controlled foreign corporation group financing exemptions as illegal state aid and has now been upheld by the General Court of the European Union. They argue that unlike the commission’s previous state aid cases, which hinged on private rulings involving preferential treatment by tax authorities, the case constitutes a fundamental challenge to the design of a country’s CFC regime