
Article 1 
The scheme on the fiscal carry-forward of losses in case of restructuring of companies in difficulty under § 8c(1a) KStG (Sanierungsklausel) does not constitute State aid within the meaning of Article 107(1) of the Treaty on the Functioning of the European Union.
Article 2 
This Decision is addressed to the Federal Republic of Germany.
Done at Brussels, 22 January 2020.
For the Commission
Margrethe VESTAGER
Executive Vice-President