The UK CFC State Aid Saga: Chronicle of a Death Foretold

The purpose of this article is to outline the key issues raised in the UK controlled foreign companies (CFC) case which is currently being litigated before EU Courts. This case involves the alleged grant of unlawful State aid by the United Kingdom to certain multinational companies via the group financing exemption included within CFC rules. This article describes the state of play in this ongoing State aid saga and argues that the ECJ should follow the Opinion of Advocate General Medina and conclude that State aid was not granted.