The Controlled Foreign Companies (Reversal of State Aid Recovery) Regulations 2024

Schedule 7ZA (“Schedule 7ZA”) to the Taxation (International and Other Provisions) Act 2010 made provision to recover State aid found to be unlawful by the Commission Decision (EU) 2019/1352 of 2 April 2019 on the state aid SA.44896 implemented by the United Kingdom concerning the CFC Group Financing Exemption. These Regulations are made following the annulment of that decision to put, so far as is reasonably practicable, any company affected by Schedule 7ZA back in the position it would have been in if the Commission Decision had not been made and that Schedule had not had effect.