Europaudvalget 2021-22
EUU Alm.del Bilag 14
Offentligt
2459712_0001.png
NOTE
8 October 2021
Danish Government response to the urgent consultation on the 6th
amendment of Temporary Framework for State aid measures to sup-
port the economy in the current COVID-19 outbreak
The Danish Government welcomes the Commission’s
proposal to a 6
th
amendment to the Temporary Framework clarifying the Covid-19 state aid
regime for 2022 and 2023.
Since its first adoption in March 2020 the Temporary Framework has been
a very useful tool in order to cope with the negative impact on the economy
and undertakings during the Covid-19 outbreak.
In particular, we welcome the proposal to increase the aid ceiling of the
uncovered fixed cost measures to 12 mil. Euro in order to address the pro-
longed economic effects of the ongoing crisis caused by the long duration
of restrictions and former lockdowns.
Please, find below our comments to the draft 6
th
amendment.
1. Prolongation
The Danish Government accepts a general prolongation of the measures set
out in the Temporary Framework until 30 June 2022 while maintaining the
objective of returning to the normal state aid regime as soon as the situation
allows it.
Furthermore, we agree that it is necessary to enable the conversion of
repayable aid instruments into other forms of aid under section 3.1 and
section 3.12 of the Temporary Framework until 30 June 2023.
2. Section 3.12
increased ceiling
We support the proposal for an increase of the aid ceiling in section 3.12 of
the Temporary Framework, which enables targeted support to companies
that experienced significant turnover losses.
In order to meet the requirements of the companies particularly affected by
COVID-19 and the long duration of restrictions and former lockdowns
Denmark advocates for an increase of the aid ceiling of Temporary Frame-
work 3.12 with a minimum of 25 pct. so that the aid ceiling corresponds to
EUU, Alm.del - 2021-22 - Bilag 14: Notat samt høringssvar vedr. ændring og forlængelse af midlertidige rammebetingelser for statsstøttetiltag ifm. til COVID-19
2/2
the prolongation of the Temporary Framework measures until 30 June
2022.
3. New provisions enabling sustainability investment (TF 3.13)
and solvency support (TF 3.14)
We welcome the introduction of the new provisions enabling sustainability
investment and solvency support.
The possibility to support private investment as a stimulus to overcome an
investment gap accumulated in the economy due to the crisis is very appro-
priate.
As set out in point 52 of the draft 6
th
amendment to the Temporary Frame-
work such a stimulus could facilitate the development of certain economic
activities or of certain economic areas, and we welcome the fact that the
Commission will consider such measures compatible with the internal mar-
ket under Article 107(3)(c) TFEU if the conditions are met.
We also welcome the possibility to support the economic recovery by
strengthening the solvency undertakings, and we find it necessary that the
Commission will consider such schemes compatible with the internal mar-
ket under Article 107(3)(c) TFEU if the conditions are met.
4. Application of article 107(3)(b)
We appreciate the Commission's proposal to clarify and amend the scope
of TFEU article 107(3)(b) in the proposed new recital 41.
5. Short-term export-credit
insurance (“STEC”)
We support that the Commission will continue to consider all commercial
and political risks associated with exports to the countries listed in the
Annex to the STEC as temporarily non-marketable until 30 June 2022.
Hence, we support the proposal to amend the list of marketable risk coun-
tries set out in the Annex to the STEC.
6. Other points
the concept of a single undertaking and in-
creased aid ceiling in Section 3.1
We invite the Commission to include a clarification of the concept and def-
inition of a single undertaking in the revision of the Temporary Framework.
Finally, the Danish Government urges the Commission to increase the aid
ceiling in Section 3.1 with a minimum of 25 pct. for the same reasons as
mentioned above.