7. marts 2023
Response by the Danish Government to the European Commission’s
draft for the implementing regulation for the foreign subsidies
The Danish Government appreciates the opportunity to comment on the
Commission’s draft for the implementing regulation for the foreign subsi-
dies.
The Danish Government overall supports the regulation on foreign subsi-
dies as it introduces the necessary supplementary tool to handle unfair com-
petition in the Single Market without being able to be abused to protection-
ism. This is highly important, as EU openness to international trade and
investments are preconditions for pursuing our strategic autonomy and
competitiveness.
As highlighted in the negotiations it is important that the regulation does
not put unnecessary administrative burden on companies. Therefore, we
have the following comments for the procedural rules:
As regards the concept of
‘financial contributions’
there is a need for more
clarity in terms if which types of transactions are covered by this term, so
that companies are given the best possible conditions to meet the reporting
requirement. However, it should not have consequences for the enforce-
ment of the regulation, as it is important to handle unfair competition.
The Commission should also consider effective ways on how companies
can handle documents (e.g. looking at possibilities to handle information at
an aggregate level). In this regard, it is important the Commission also care-
fully consider how to protect companies' sensitive information. Especially
in view of the fact that the companies are required to submit information
on behalf of his sub-supplier(s).
In order to simplify the notifications, it might be effective to look at sim-
plified procedures for transactions under EUR 4 million over any consecu-
tive period of three years.