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Case C-54/19 P: Judgment of the Court (Grand Chamber) of 6 October 2021 — Axa Mediterranean Holding SA v European Commission (Appeal — State aid — Article 107(1) TFEU — Tax system — Corporate tax provisions allowing undertakings which are tax resident in Spain to amortise the goodwill resulting from the acquisition of shareholdings in companies which are tax resident outside that Member State — Concept of ‘State aid’ — Condition relating to selectivity — Reference system — Derogation — Difference in treatment — Justification for the difference in treatment)
ECLI:EU:UNKNOWN:62019CA0054
62019CA0054
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29.11.2021
Official Journal of the European Union
C 481/5
(Case C-54/19 P) (<span class="oj-super oj-note-tag">1</span>)
(Appeal - State aid - Article 107(1) TFEU - Tax system - Corporate tax provisions allowing undertakings which are tax resident in Spain to amortise the goodwill resulting from the acquisition of shareholdings in companies which are tax resident outside that Member State - Concept of ‘State aid’ - Condition relating to selectivity - Reference system - Derogation - Difference in treatment - Justification for the difference in treatment)
(2021/C 481/07)
Language of the case: Spanish
Parties
Appellant: Axa Mediterranean Holding SA (represented by: J.L. Buendía Sierra, E. Abad Valdenebro, R. Calvo Salinero and A. Lamadrid de Pablo, abogados)
Other party to the proceedings: European Commission (represented by: R. Lyal, B. Stromsky, C. Urraca Caviedes and P. Němečková, Agents)
Operative part of the judgment
The Court:
1.Dismisses the appeal;
2.Orders Axa Mediterranean Holding SA to pay the costs.
(<span class="oj-super">1</span>) OJ C 112, 25.3.2019.