Tax law expert Jason Collins of Pinsent Masons said the rise in notifications was likely to be linked to a clampdown by authorities on tax avoidance by businesses.
“Offering favourable tax treatment on a selective basis to multinational businesses has become an important method by which many countries attract inward investment. However, in this era of the war on tax avoidance this has become more controversial,” Collins said.
“The European Commission has been taking a more aggressive stance towards possible anti-competitive behaviour and has the tax treatment of multinationals very much in its sights,” Collins said.
“The complexities of the tax rules in some EU member states is also likely to have driven the increase in the number of notifications. Other factors, such as tax breaks provided to investments in a country’s overseas territories or to encourage investment in certain industries, could also count,” Collins said.
The European Commission carried out a number of investigations into tax rulings by several member states, particularly in Ireland, Luxembourg and the Netherlands, from 2013. Companies which have come under the spotlight included Apple, Starbucks, Amazon, ENGIE and Fiat, with the Commission finding in all of those cases that unlawful state aid had been given.
Fast food giant McDonald’s was also investigated, but no breach of state aid laws was discovered in its case.
In April 2019, the commission said the UK's Controlled Foreign Company (CFC) rules partly contravened EU state aid rules and that the UK must require repayment from companies that have benefited.