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Clifford Chance

Clifford Chance
Briefings

Briefings

Apple Loses the €13 Billion Tax Ruling State Aid Case

24 September 2024

In a final, non-appealable judgment, the Court of Justice of the EU sided with the European Commission (EC) and found that Ireland granted Apple illegal State aid by means of advance tax rulings. The judgment is a major political victory for the EC, after it had lost similar cases concerning tax rulings granted by the Netherlands (Starbucks) and Luxembourg (Fiat, Amazon, and Engie). The different outcome in Apple turns on the specifics of Apple's corporate and tax structure in Ireland and Ireland's tax law.

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