CELEX:62020CA0705: Case C-705/20: Judgment of the Court (Second Chamber) of 15 September 2022 (request for a preliminary ruling from the Income Tax Tribunal of Gibraltar (United Kingdom) — United Kingdom) — Fossil (Gibraltar) Limited v Commissioner of Income Tax (Reference for a preliminary ruling — State aid — Aid schemes implemented by the Government of Gibraltar concerning corporate income tax — Decision (EU) 2019/700 — Non-taxation of passive interest and royalty income — Decision of the European Commission declaring the aid scheme unlawful and incompatible with the internal market — Recovery obligation — Scope — Domestic provision which was not the subject of the Commission’s investigation concerning the State aid at issue — Set-off of the tax paid abroad in order to prevent double taxation)