Uzasadnienie
OPINION OF ADVOCATE GENERAL
BIONDI
delivered on 25 June 2026 (1)
Case C‑670/24 P
Mead Johnson Nutrition (Asia Pacific) Pte Ltd,
MJN Global Holdings BV,
Mead Johnson Nutrition Co.
v
European Commission
( Appeal – State aid – United Kingdom – Gibraltar corporate income tax regime – Tax exemption for income generated by interest and intellectual property royalties – Advance tax rulings in favour of multinational undertakings – Decision to extend the formal investigation procedure laid down in Article 108(2) TFEU – Aid measure implemented on the date of the decision – Action for annulment – Definition of ‘act open to challenge’ )
I. Introduction
1. In the present appeal, the Court is called upon primarily to rule on the consistency of a line of case-law developed by the General Court regarding the inadmissibility, under certain circumstances, of actions for annulment brought against European Commission’s decisions to initiate the formal investigation procedure laid down in Article 108(2) TFEU and Article 4(4) of Council Regulation (EU) 2015/1589 of 13 July 2015 laying down detailed rules for the application of Article 108 of the Treaty on the Functioning of the European Union. (2)