
Article 1 

1. The State aid scheme in the form of the passive interest income tax exemption applicable in Gibraltar under the Income Tax Act 2010 between 1 January 2011 and 30 June 2013 and unlawfully put into effect by Gibraltar in contravention of Article 108(3) of the Treaty is incompatible with the internal market within the meaning of Article 107(1) of the Treaty.
2. The State aid scheme in the form of the royalty income tax exemption applicable in Gibraltar under the Income Tax Act 2010 between 1 January 2011 and 31 December 2013 and unlawfully put into effect by Gibraltar in contravention of Article 108(3) of the Treaty is incompatible with the internal market within the meaning of Article 107(1) of the Treaty.
Article 2 
The individual State aids granted by the Government of Gibraltar, on the basis of the tax rulings (referred to in the Annex as rulings No 83, 84, 139, 140 and 144) to five Gibraltar companies with interests in Dutch limited partnerships (Commanditaire Vennootschappen) in receipt of royalty and passive interest income, which were unlawfully put into effect by the United Kingdom in contravention of Article 108(3) of the Treaty, are incompatible with the internal market within the meaning of Article 107(1) of the Treaty.
Article 3 

1. The tax ruling practice under the Income Tax Act 2010 does not constitute a State aid scheme within the meaning of Article 107(1) of the Treaty.
2. The 126 rulings, listed in the Annex to this Decision, other than the five rulings covered by Article 2 and the 34 rulings referred to in recital 144, do not constitute individual State aids within the meaning of Article 107(1) of the Treaty.
Article 4 

1. Articles 1 and 2 of this Decision shall not apply to individual aid granted on the basis of the aid schemes referred to in Article 1 or on the basis of the tax rulings referred to in Article 2 if, at the time the individual aid was granted, it fulfilled the conditions laid down by the Regulation adopted pursuant to Article 2 of Council Regulation (EC) No 994/98 which was applicable at the time the aid was granted.
2. For the purposes of this Article and Article 5, individual aid is deemed to be put at a beneficiary's disposal, with respect to each tax year, on the day that the tax foregone for that tax year as a result of the aid schemes referred to in Article 1 or the tax rulings referred to in Article 2 would have fallen due in the absence of that scheme or ruling.
Article 5 

1. The United Kingdom shall recover all incompatible aid granted on the basis of the aid schemes referred to in Article 1 or on the basis of the tax rulings referred to in Article 2, from the beneficiaries of that aid.
2. Any individual aid granted on the basis of the tax rulings referred to in Article 2 which cannot be recovered from the Gibraltar company in question shall be recovered from other entities forming a single economic unit with that Gibraltar company, i.e. the relevant Dutch BV, the Dutch CV or the parent company of the Gibraltar company.
3. The sums to be recovered shall bear interest from the date on which they were put at the disposal of the beneficiary until their actual recovery.
4. The interest shall be calculated on a compound basis in accordance with Chapter V of Commission Regulation (EC) No 794/2004.
5. The United Kingdom shall cease granting the aid on the basis of the aid schemes referred to in Article 1 or the tax rulings referred to in Article 2, with effect from the date of notification of this Decision.
Article 6 

1. Recovery of the aid in accordance with Article 5 shall be immediate and effective.
2. The United Kingdom shall ensure that this Decision is implemented within four months from the date of notification of this Decision.
Article 7 

1. Within two months from the date of notification of this Decision, the United Kingdom shall submit the following information to the Commission:
(a) an assessment, for each Gibraltar company that generated passive interest income in the period between 1 January 2011 and 30 June 2013, of whether such interest income accrued in or was derived from Gibraltar, based on the ‘situs of the loan’ rule;
(b) a list of beneficiaries that have received aid on the basis of the aid schemes referred to in Article 1, together with the following information for each of them and for each relevant tax year:
— the amount of profits achieved (indicating separately the profits achieved from royalty income and the profits achieved from passive interest income), the tax basis, the applicable income tax rate, the amount of income tax paid and the amount of the tax foregone,
— the total amount of aid received;
(c) the following information for each of the five Gibraltar companies that received aid on the basis of the tax rulings referred to in Article 2 and for each relevant tax year:
— the amount of profits achieved (indicating separately the profits achieved from royalty income and the profits achieved from passive interest income), the tax basis, the applicable income tax rate, the amount of income tax paid and the amount of the tax foregone,
— the total amount of aid received;
(d) the total amount (principal and recovery interests) to be recovered from each beneficiary (for all tax years subject to recovery);
(e) a detailed description of the measures already taken, and of those planned, in order to comply with this Decision;
(f) documents demonstrating that the beneficiaries have been ordered to repay the aid.
2. The United Kingdom shall keep the Commission informed of the progress of the national measures taken to implement this Decision until recovery of the aid in accordance with Article 5 has been completed. On request by the Commission, it shall submit to the Commission information on the national measures already taken, and on those planned, in order to comply with this Decision.
Article 8 
This Decision is addressed to the United Kingdom of Great Britain and Northern Ireland.
Done at Brussels, 19 December 2018.
For the Commission
Margrethe VESTAGER
Member of the Commission
ANNEX

Company Name Granting Date Description of the activities Classification of Ruling (in light of Section 8.2.1)

1. KaiRo Management Limited
 7.1.2011 Services, management consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

2. Thurlestone Shipping (Overseas) Limited
 10.1.2011 Services, shipping intermediary Application of territoriality principle. No income accrued in or derived from Gibraltar.

3. Mina Corp Limited
 10.1.2011 Trade, sale of petroleum products Application of territoriality principle. No income accrued in or derived from Gibraltar.

4. Red Star Enterprises Limited
 10.1.2011 Trade, sale of petroleum products Application of territoriality principle. No income accrued in or derived from Gibraltar.

5. BO (Middle East) Limited
 12.1.2011 Trade, importation of furniture Application of territoriality principle. No income accrued in or derived from Gibraltar.

6. THE One (Middle East) Limited
 12.1.2011 Trade, importation of furniture Application of territoriality principle. No income accrued in or derived from Gibraltar.

7. THE One Retail Network (International) Limited
 12.1.2011 Holding company, licensing intellectual property Passive income exemption. Situation regularised after legislative changes or activities ceased.

8. THE One Music Limited
 12.1.2011 Trade, manufacture and sale of CDs Application of territoriality principle. No income accrued in or derived from Gibraltar.

9. Prospective Company
 12.1.2011 Holding company, licensing intellectual property Company was not incorporated, activities did not materialise or the company was dormant

10. Link Holdings (Gibraltar) Limited
 14.1.2011 Trade, income from rents Application of territoriality principle. No income accrued in or derived from Gibraltar.

11. European Mail Union Limited
 28.1.2011 Trade, provision of mail forwarding Application of territoriality principle. No income accrued in or derived from Gibraltar.

12. Ansellia Aviation Limited
 31.1.2011 Holding of assets, property (aircraft) Application of territoriality principle. No income accrued in or derived from Gibraltar.

13. Prospective Company
 4.2.2011 Beneficiary in a trust Company was not incorporated, activities did not materialise or the company was dormant

14. Prospective Company
 7.2.2011 Provision of loan(s) Company was not incorporated, activities did not materialise or the company was dormant

15. Zartello Limited
 7.2.2011 Trade, marketing services Application of territoriality principle. No income accrued in or derived from Gibraltar.

16. Gol International Limited
 10.2.2011 Trade, sports agent Application of territoriality principle. No income accrued in or derived from Gibraltar.

17. Graf Von Bismark and Associated Limited
 21.2.2011 Trade, provision of asset managers Application of territoriality principle. No income accrued in or derived from Gibraltar.

18. Medifour Limited
 25.2.2011 Trade, sale of medical products Application of territoriality principle. No income accrued in or derived from Gibraltar.

19. Current Technology (Europe) Limited
 25.2.2011 Trade, marketing Company was not incorporated, activities did not materialise or the company was dormant

20. Corporate Consultants Limited
 25.2.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

21. Alphasol Limited
 25.2.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

22. Akasha Charters Limited
 25.2.2011 Trade, yacht chartering Application of territoriality principle. No income accrued in or derived from Gibraltar.

23. Osato Industries Limited
 28.2.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

24. Gambit Management Services Limited
 1.3.2011 Holding of property and consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

25. Greatheart Underwriting Limited
 4.3.2011 Investment holding company Application of territoriality principle. No income accrued in or derived from Gibraltar.

26. UNILOG, United Logistics & Shipping Operators Limited
 9.3.2011 Trade, management of shipping line Application of territoriality principle. No income accrued in or derived from Gibraltar.

27. Continental Maritime Limited
 15.3.2011 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

28. Baby Basics Limited
 15.3.2011 Trade, marketing Application of territoriality principle. No income accrued in or derived from Gibraltar.

29. Baby Basics (Iberia) Limited
 15.3.2011 Trade, marketing and sales, training Company was not incorporated, activities did not materialise or the company was dormant

30. Baby Basics (International) Limited
 15.3.2011 Trade, distribution of products Application of territoriality principle. No income accrued in or derived from Gibraltar.

31. Baby Basics (Asia) Limited
 15.3.2011 Trade, marketing and sales, training Application of territoriality principle. No income accrued in or derived from Gibraltar.

32. Family Roots Limited
 15.3.2011 Trade, marketing Application of territoriality principle. No income accrued in or derived from Gibraltar.

33. Western Mediterranean Holdings Limited
 16.3.2011 Investment holding company Passive income exemption. Situation regularised after legislative changes or activities ceased.

34. M. Benady & Company (Gibraltar) Limited
 16.3.2011 Trade, management services Application of territoriality principle. No income accrued in or derived from Gibraltar.

35. Prime Ideas Limited
 18.3.2011 Holding intellectual property rights Passive income exemption. Situation regularised after legislative changes or activities ceased.

36. Hattrick Limited
 21.3.2011 Services, consultancy and advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

37. Tubingen Limited
 22.3.2011 Asset holding company, motor yacht Application of territoriality principle. No income accrued in or derived from Gibraltar.

38. Channel Energy (Eire) Limited
 24.3.2011 Trade, storage and handling of petroleum Application of territoriality principle. No income accrued in or derived from Gibraltar.

39. Crane Trading Corporation Limited
 24.3.2011 Trade, motors Application of territoriality principle. No income accrued in or derived from Gibraltar.

40. Europe Income Real Estate Limited
 25.3.2011 Provision of loan(s) Company was not incorporated, activities did not materialise or the company was dormant

41. IMAAG Limited
 25.3.2011 Services, consultancy and advisory Company was not incorporated, activities did not materialise or the company was dormant

42. Prospective Company
 28.3.2011 Trade, marketing services Application of territoriality principle. No income accrued in or derived from Gibraltar.

43. Jonsden Properties Limited
 28.3.2011 Trade, marketing services Application of territoriality principle. No income accrued in or derived from Gibraltar.

44. Ellise Trading Group Limited
 28.3.2011 Holding, intellectual property Application of territoriality principle. No income accrued in or derived from Gibraltar.

45. Kamakura Investments Limited
 29.3.2011 Investment holding Passive income exemption. Situation regularised after legislative changes or activities ceased.

46. Prospective Company
 1.4.2011 Trade, advertising Company was not incorporated, activities did not materialise or the company was dormant

47. Roxbury Limited
 1.4.2011 Holding of patents and trademarks Passive income exemption. Situation regularised after legislative changes or activities ceased.

48. Roger Bullivant Holdings Limited
 1.4.2011 Group Holding Application of territoriality principle. No income accrued in or derived from Gibraltar.

49. Horizon Ventures Limited
 1.4.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

50. Nidham Holdings Limited
 1.4.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

51. AMD Limited
 1.4.2011 Trade, sale of agricultural products Application of territoriality principle. No income accrued in or derived from Gibraltar.

52. Cookstown Properties Limited
 5.4.2011 Holding, company shares Application of territoriality principle. No income accrued in or derived from Gibraltar.

53. Burlington English Limited
 7.4.2011 Services, consultancy and advisory Company was not incorporated, activities did not materialise or the company was dormant

54. Burlington Marketing Limited
 7.4.2011 Services, consultancy and advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

55. Burlington English Limited
 11.4.2011 Services, consultancy and advisory Company was not incorporated, activities did not materialise or the company was dormant

56. Burlington Marketing Limited
 11.4.2011 Services, consultancy and advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

57. Eastcheap Trading Corporation Limited
 14.4.2011 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

58. Horizon Ventures Limited
 14.4.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

59. Keystone Shipping Limited
 4.5.2011 Trade, bareboat chartering Application of territoriality principle. No income accrued in or derived from Gibraltar.

60. World Rugby League (Europe) Limited
 6.5.2011 Trade, marketing services Application of territoriality principle. No income accrued in or derived from Gibraltar.

61. World Rugby League Limited
 6.5.2011 Trade, marketing services Application of territoriality principle. No income accrued in or derived from Gibraltar.

62. Lobric Properties Limited
 6.5.2011 Trade, sale of agricultural products Application of territoriality principle. No income accrued in or derived from Gibraltar.

63. Bushman Limited
 6.5.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

64. Key Retail Technologies Limited
 9.5.2011 Services, management and consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

65. Kinsman Trustees Limited
 11.5.2011 Services, provision of trustees Application of territoriality principle. No income accrued in or derived from Gibraltar.

66. Amicus Trustees Limited
 11.5.2011 Services, provision of trustees Application of territoriality principle. No income accrued in or derived from Gibraltar.

67. Benamara Limited
 11.5.2011 Investment holding Passive income exemption. Situation regularised after legislative changes or activities ceased.

68. Halstead Investments Limited
 11.5.2011 Investment holding Passive income exemption. Situation regularised after legislative changes or activities ceased.

69. Nightingale Investments Limited
 11.5.2011 Trade, supply of oil and gas equipment Application of territoriality principle. No income accrued in or derived from Gibraltar.

70. JST (International) Company Limited
 11.5.2011 Services, consultancy and advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

71. The Consultants Limited
 11.5.2011 Services, consultancy and advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

72. Birchall Properties Limited
 17.5.2011 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

73. Cookstown Properties Limited
 19.5.2011 Property and investments holding Application of territoriality principle. No income accrued in or derived from Gibraltar.

74. Paramount Healthcare Consulting Limited
 20.5.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

75. Swerford Holdings Limited
 20.5.2011 Trade, gaming Ruling related to personal income tax and does not involve a company subject to corporate income tax

76. Orios Limited
 23.5.2011 Trade, online flower and gift retailer Application of territoriality principle. No income accrued in or derived from Gibraltar.

77. Bushman Limited
 23.5.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

78. Nautilus Limited
 1.6.2011 Asset holding, motor yacht Application of territoriality principle. No income accrued in or derived from Gibraltar.

79. Salamba Shipping Limited
 1.6.2011 Asset holding, motor yacht Application of territoriality principle. No income accrued in or derived from Gibraltar.

80. Repset Limited
 1.6.2011 Group Holding Application of territoriality principle. No income accrued in or derived from Gibraltar.

81. McWane (Gibraltar) Holdings Limited
 2.6.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

82. McWane (Gibraltar) Limited
 2.6.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

83. Heidrick and Struggles (Gibraltar) Holdings Limited.
 2.6.2011 Provision of loan(s) Contested ruling

84. 
Limited, GibCo2)
 2.6.2011 Provision of loan(s) Contested ruling

85. Walstead Limited
 8.6.2011 Trade, marketing, sales and research Application of territoriality principle. No income accrued in or derived from Gibraltar.

86. Meritas (Gibraltar) Holdings Limited
 8.6.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

87. Perpetual Systems Limited
 9.6.2011 Trade in Gibraltar Ruling related to personal income tax and does not involve a company subject to corporate income tax

88. Loksys (International) Limited
 15.6.2011 Trade in Gibraltar Ruling related to personal income tax and does not involve a company subject to corporate income tax

89. Lawnsvale Investments Limited
 16.6.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

90. Oilcom Agency Limited
 24.6.2011 Trade, buying and selling of clothing Application of territoriality principle. No income accrued in or derived from Gibraltar.

91. CT Marketing Limited
 30.6.2011 Services, consultancy and marketing Application of territoriality principle. No income accrued in or derived from Gibraltar.

92. Navigia Limited
 5.7.2011 Services, consultancy Application of territoriality principle. No income accrued in or derived from Gibraltar.

93. Ocean Pride Shipping Co. Limited
 5.7.2011 Asset holding, motor yacht Application of territoriality principle. No income accrued in or derived from Gibraltar.

94. Equilibrium Management Limited
 11.7.2011 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

95. Taylan Limited
 11.7.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

96. Prospective Company
 12.7.2011 Trade, currency exchange Company was not incorporated, activities did not materialise or the company was dormant

97. Galva Investments Limited
 13.7.2011 Investment holding Application of territoriality principle. No income accrued in or derived from Gibraltar.

98. Uniphos Limited
 13.7.2011 Services, consultancy and marketing Application of territoriality principle. No income accrued in or derived from Gibraltar.

99. Prospective Company (Advisory Limited)
 14.7.2011 Provision of loan(s) Company was not incorporated, activities did not materialise or the company was dormant

100. Prospective company
 22.7.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

101. Prospective company
 5.8.2011 Trade, marketing Application of territoriality principle. No income accrued in or derived from Gibraltar.

102. Hastings Insurance Group Limited
 11.8.2011 Group Holding Ruling related to personal income tax and does not involve a company subject to corporate income tax

103. Patron Capital G.P. III Limited
 17.8.2011 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

104. Vantini Spur Limited
 14.9.2011 Holding intellectual property Passive income exemption. Situation regularised after legislative changes or activities ceased.

105. Tubman (International) Limited
 14.9.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

106. Tubman (Holdings) Limited
 14.9.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

107. Broadstreet (Gibraltar) Limited
 30.9.2011 Services, consultancy and loan interest Passive income exemption. Situation regularised after legislative changes or activities ceased.

108. Biomet (International) Limited
 6.10.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

109. Biomet (Gibraltar) Holdings Limited
 6.10.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

110. Biomet Inc
 6.10.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

111. Biomet S.a.r.l
 6.10.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

112. Waterside (International) Limited
 8.11.2011 Services, management advisory Application of territoriality principle. No income accrued in or derived from Gibraltar.

113. 
International Law Firm)
 16.11.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

114. Infor (Gibraltar) Limited
 22.11.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

115. Miller International Limited
 24.11.2011 Trade, sale of earth moving products Application of territoriality principle. No income accrued in or derived from Gibraltar.

116. Tipico Services Limited
 29.11.2011 Services, administrative support Application of territoriality principle. No income accrued in or derived from Gibraltar.

117. Select Sports Management Limited
 16.12.2011 Services, consultancy football agent Application of territoriality principle. No income accrued in or derived from Gibraltar.

118. Allabroad Limited
 16.12.2011 Trade, sailing tuition and yacht charters Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

119. Prospective Company
 16.12.2011 Services, administrative support Company was not incorporated, activities did not materialise or the company was dormant

120. Delphi Automotive Services (Gibraltar) Limited
 20.12.2011 Subsidiary company Passive income exemption. Situation regularised after legislative changes or activities ceased.

121. 8F Leasing (Gibraltar) Limited
 22.12.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

122. 8F Leasing S.A.
 22.12.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

123. 8F leasing (Bermuda) Limited
 22.12.2011 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

124. Scan Truck & Trailer Rental Limited
 3.1.2012 Trade, truck and trailer rental Application of territoriality principle. No income accrued in or derived from Gibraltar.

125. Matterhorn Holdings Limited
 16.1.2012 Trade, Sale of IT materials Application of territoriality principle. No income accrued in or derived from Gibraltar.

126. 8F Leasing (Gibraltar) Limited
 3.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

127. 8F Leasing (Bermuda) Limited
 3.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

128. 8F Leasing S.A.
 3.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

129. 8F Leasing (Gibraltar) Limited
 20.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

130. 8F Leasing (Bermuda) Limited
 20.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

131. 8F Leasing S.A.
 20.2.2012 Provision of loan(s) Passive income exemption. Situation regularised after legislative changes or activities ceased.

132. Zaida Company Limited
 2.3.2012 Trade, fees and commissions on payments Application of territoriality principle. No income accrued in or derived from Gibraltar.

133. Rowan Gorilla V (Gibraltar) Limited
 29.3.2012 Trade, oil well drilling rig (charter) Application of territoriality principle. No income accrued in or derived from Gibraltar.

134. Rowan Gorilla VII (Gibraltar) Limited
 29.3.2012 Trade, oil well drilling rig (charter) Application of territoriality principle. No income accrued in or derived from Gibraltar.

135. Rowan Cayman Limited
 29.3.2012 Trade, oil well drilling rig (charter) Company was not incorporated, activities did not materialise or the company was dormant

136. Rowan Drilling (Gibraltar) Limited
 29.3.2012 Trade, oil well drilling rig (charter) Application of territoriality principle. No income accrued in or derived from Gibraltar.

137. Rowan Drilling Norway AS
 29.3.2012 Trade, oil well drilling rig (charter) Application of territoriality principle. No income accrued in or derived from Gibraltar.

138. Kiluya Employment Management Limited
 3.5.2012 Services, provision of engineers Application of territoriality principle. No income accrued in or derived from Gibraltar.

139. Ash (Gibraltar) One Limited
 8.5.2012 Subsidiary of chemical company Contested ruling

140. Ash (Gibraltar) Two Limited
 8.5.2012 Subsidiary of chemical company Contested ruling

141. Prospective Company
 12.6.2012 Holding intellectual property Company was not incorporated, activities did not materialise or the company was dormant

142. Partner Invest Limited
 21.8.2012 Trade, company incorporation Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

143. Partner Invest Limited
 21.8.2012 Trade, company incorporation Application of territoriality principle. No income accrued in or derived from Gibraltar.

144. MJN Holdings (Gibraltar) Limited
 11.9.2012 Subsidiary in group structure Contested ruling

145. Fidux Trust Company Limited
 9.10.2012 Trade, provision of trust services Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar

146. OED Limited
 4.1.2013 Trade, software development Application of territoriality principle. No income accrued in or derived from Gibraltar.

147. Sunbreeze Limited
 12.2.2013 Trade, online broker Application of territoriality principle. No income accrued in or derived from Gibraltar.

148. Prospective Company
 12.4.2013 Holding intellectual property Company was not incorporated, activities did not materialise or the company was dormant

149. Promo 6000 International Limited
 22.4.2013 Trade, marketing and advertising Application of territoriality principle. No income accrued in or derived from Gibraltar.

150. Visavi 5x5 Limited
 22.4.2013 Trade, website portals Application of territoriality principle. No income accrued in or derived from Gibraltar.

151. Visavi Activities Limited
 22.4.2013 Holding company shares Application of territoriality principle. No income accrued in or derived from Gibraltar.

152. Visavi Spins Limited
 22.4.2013 Trade, website portals Application of territoriality principle. No income accrued in or derived from Gibraltar.

153. Visavi Portals Limited
 22.4.2013 Trade, website portals Application of territoriality principle. No income accrued in or derived from Gibraltar.

154. Prospective Company
 10.5.2013 Holding intellectual property Company was not incorporated, activities did not materialise or the company was dormant

155. Scanlan Worldwide Limited
 21.5.2013 Trade, buying, importing and exporting Application of territoriality principle. No income accrued in or derived from Gibraltar.

156. Rebecca (Holdings) Limited
 10.6.2013 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

157. IAPA (Global) Limited
 24.6.2013 Trade, master policy insurance cover Application of territoriality principle. No income accrued in or derived from Gibraltar.

158. Collinson Group (Trademarks) Limited
 24.6.2013 Holding intellectual property Passive income exemption. Situation regularised after legislative changes or activities ceased.

159. Rebecca (Holdings) Limited
 28.6.2013 Provision of loan(s) Application of territoriality principle. No income accrued in or derived from Gibraltar.

160. Innophus (Gibraltar) Limited
 2.8.2013 Trade, industrial manufacturing Company was not incorporated, activities did not materialise or the company was dormant

161. Stabalis Limited
 22.11.2013 Services, provision of consulting intra-group services Application of territoriality principle. No income accrued in or derived from Gibraltar.

162. J Domains Limited
 20.12.2013 Services, management of domain sales Application of territoriality principle. No income accrued in or derived from Gibraltar.

163. Prospective Company
 23.12.2013 Trade, supply of merchandise Company was not incorporated, activities did not materialise or the company was dormant

164. Potential immigrant
 23.12.2013 Employee Ruling related to personal income tax and does not involve a company subject to corporate income tax

165. British Virgin Islands Company
 23.12.2013 Trade, provision of digital products such as online training courses Effectively subject to tax. Income accrued and derived in Gibraltar and therefore taxable in Gibraltar
Note: the numbering of the companies follows the numbering of the annex of the decision to extend proceedings.For the sake of completeness, the table includes the five contested tax rulings with numbers 83, 84, 139, 140 and 144.