The Court of Justice upholds the annulment of the European Commission’s third decision on the scheme for the tax amortisation of financial goodwill

The judgment of the Court of Justice of 26 June 2025 concludes that the first two decisions of the European Commission on the incompatibility with State aid rules of the scheme for the tax amortisation of financial goodwill gave rise to a legitimate expectation as to the scope and limits of the recovery obligation, including within its scope direct and indirect acquisitions of shareholdings in foreign companies. Therefore, aid related to indirect acquisitions covered by the first two decisions cannot be recovered retroactively and should be returned together with late payment interest.

Download document

View document