Mr. Seamus Coffey:

Not in general. The change itself is not necessarily offering preferential treatment with regard to the regime. The granting of capital allowances for acquisitions of intangibles is common across almost all tax regimes, particularly those that apply tax depreciation. We looked at 27 of the 28 EU countries that offer it and the country that does not has a cash deduction system - an upfront deduction for the amount one spends. The common consolidated corporate tax base, CCCTB, has capital allowances for intangible assets and there is no cap on it. The cap is a base protection measure. Even at 100%, the cap offers protection that other countries will not necessarily have in place because we do not want a situation where if a company was to overpay for an asset and did not generate profits, if it still had the capital allowances, it could claim them every year and generate losses. The treatment of losses in the tax code is different to the treatment of capital allowances because losses can be distributed around a group so if a company overpaid for an asset and did not have profits, those losses could be used to offset profits elsewhere. The 100% cap prevents those losses from being generated. It limits the capital allowances used to the amount of profit. The cap itself is a base protection measure that some other countries may not have. I do not see risks of state aid in general from the change from 80% to 100%.