Erhvervsudvalget 2020-21
ERU Alm.del Bilag 72
Offentligt
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08 November 2020
Danish response to the consultation on review of the Commission's
Guidelines on Regional State Aid
We welcome the opportunity to share the Danish views on the review of the
Regional Aid Guidelines (RAG). Please find below our general comments to
the draft guidelines as well as our specific comments addressing four specific
elements of the RAG., which we urge the Commission to take into considera-
tion in the process of reviewing the RAG.
1. General comments
Denmark in general finds that the existing RAG have played and continuously
play an important role in the regulation of the Single Market. State aid control
in general contributes to maintaining a level playing field for undertakings in
the Single Market. Hence, Denmark endorses a transparent and effective state
aid control in the EU.
Since their adoption in 2014 the current RAG has in general contributed to
well-designed state aid schemes and individual aid in Member States targeted
at identified market failures and objectives of common interest. Hence, the
state aid rules adopted in 2014 are generally fit for purpose.
Our main application of the RAG has been related to designate areas eligible
for financing in the Regional aid map. This designation procedure has been
well-functioning.
Denmark’s main concern as regard regional aid is the admission in the RAG
and other state aid rules to provide subsidies to large enterprises. Public subsi-
dies for large enterprises
–
even in a- or c-regions
–
can potentially lead to
distorting effects to competitors of smaller scale, to the Single Market and for
European consumers in the very end.
2. Specific comments
Relocation
–
point 24 and 124:
Denmark would like to emphasize, that state aid rules in general should
not
lead to granting aid to relocation of jobs and undertakings from one Member
State to another. We find that provisions to safeguard relocation effects should
be included in all state aid regulations and guidelines. The clear message from
the Commission must be, that there is no European value added, if state aid is
used to move jobs around Europe with taxpayers’ money.
 ERU, Alm.del - 2020-21 - Bilag 72: EMs notat samt høringssvar vedrørende Europa-Kommissionens høring om revision af retningslinjerne for statsstøtte med regionalt sigte, fra erhvervsministeren
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Therefore, we indeed support the Commission’s proposal to continue the ex-
isting safeguards against state aid for relocation purposes in the draft.
Mid-term review
–
point 190:
The provisions of the RAG should be simplified as much as possible in order
to make the general conditions for application of the RAG clear and easy to
apply. When it comes to a mid-term review of the RAG in 2024 on the basis of
the statistics in 2020-2022, we fully support the potential urgent need to make
adjustments in the Regional aid maps due to the unpredictability of the situation
in the forthcoming years due to the economical, socially and environmentally
consequences of the COVID-19-crisis. We find that this review should be car-
ried out as early as possible.
Furthermore, in order for the RAG to be an effective tool to overcome the
COVID-19 crisis, we find that the Commission should consider to increase aid
intensities for regional aid to SME's for the purpose of Covid-19 related aid.
Link to the European Green Deal and A Europe fit for the digital age:
In order to be relevant and fit for new challenges, it is our view that the RAG
must be adequate flexible to adapt new horizontal developments in respect to
climate change, the environment and emerging digitalization in particular. We
therefore fully support the efforts taken in the draft to align the guidelines with
the European Green Deal objectives. We support the efforts made to ensure
that Regional aid to the production of lignite and coal will not be considered to
be compatible with the internal market.
Aid intensities in a-areas
–
point 179:
As we have already stated in our general comments, we find that subsi-
dizing large enterprises regardless of geographical location raises con-
cerns.
In accordance with the latest statistics,
1
we have learned that some Eu-
ropean regions are eligible for support up to 50 pct. of regional invest-
ment aid. As long as there are no large enterprises but only SME’s, we
can support such high aid-intensities. However, we find that such high
aid intensities for large undertakings raises concerns and risk distortion
of competition.
We therefore suggest lowering the aid intensities to a minimum, e.g. 20
pct. for large enterprises in a-areas and maintain the proposed intensi-
ties for SME’s.
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Eurostat