Att: Commissioner Magrethe Vestager
European Commission
Rue de la Loi / Wetstraat 200
1049 Brussels
MINISTER FOR BUSINESS AND
GROWTH
23
nd
June 2016
Dear Commissioner Magrethe Vestager
Per Your request following the meeting of 20 May 2016 with the Minis-
try of Foreign Affairs the Danish government would like to thank You for
the opportunity to further elaborate on the issue of aid in connection to
relocation of undertakings and jobs in light of the proposed revision of the
GBER. We sincerely hope that the Commission will take onboard the
following concerns of the Danish government and that we can continue
communication on this issue until a satisfactory solution has been
reached.
On behalf of the Danish government I must relay our strong dissatisfac-
tion with the proposed insertion in the GBER of a compatibility criterion
of “unsubstantial” job losses resulting from a regional investment aid
beneficiary’s relocation. The Danish Government cannot accept the cur-
rent drafting of the Commission’s proposal in point 61a of the GBER to
include regional investment aid for the relocation of undertakings and
workforce which defines “Closure” to mean losses of at least a 100 jobs
or at least 50 % the workforce.
The provision should be rephrased to only include the first sentence;
“Closure of the same or similar activity’ means full closures and also
partial closures..”
and exclude any type of threshold. If a threshold is
inevitable, which the Danish government regrets, the number of 100 jobs
should be set significantly lower to accommodate the distortive effects,
that will surely come from unfair competition of state budgets, especially
in countries where the work force is mostly engaged in SMEs.
To further outline this rationale one must look at the proposed new provi-
sion in connection to the existing regional aid guidelines (RAG) for 2014-
2020, which defines such moving around of jobs as a manifestly negative
effect (recital 121, 126), unlikely to be balanced by any positive elements
-
of course, provided that that there is a causal link between the aid and
th
MINISTRY OF
BUSINESS AND GROWTH
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Denmark
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+45 33 92 33 50
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www.evm.dk