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The ACM’s priorities in 2023: the energy transition, digitalisation, and sustainability

On 26 January 2023, the ACM announced that its priorities for 2023 would be the energy transition, the digital economy, and sustainability. This agenda is unsurprising in view of the ACM’s recent policy statements and enforcement actions.

Key developments in sustainability claims in 2022

In 2022, the ACM and the European Commission put the spotlight on the accuracy of companies’ sustainability claims. Notably, the ACM published several market studies and adopted commitment decisions concerning allegedly misleading sustainability claims.

Dutch Supreme Court rules that refurbishment of former woolen fabrics factory into retail center resulted in 'essentially new constructed real estate' for VAT purposes

On Friday 11 November 2022 the Dutch Supreme Court ruled that the refurbishment of a former woolen fabrics factory into a retail centre resulted in ‘essentially new constructed real estate’ (in wezen nieuwbouw) for Dutch VAT purposes.

French supermarket dawn raids down the drain

On 9 March 2023, the European Court of Justice (ECJ) ruled that the European Commission should properly record interviews if they are used to gather information regarding the subject matter of the investigation.

Dawn raid drama: bycatch and data rooms

Beware of the fine line in antitrust investigations between illegal fishing expeditions and accidental discoveries pointing at a separate antitrust infringement.

The vertical fight continues: two more cases on vertical restraints

Companies should not take competition rules lightly in their supply relationships. The EU General Court's Valve judgment and the ACM's LG decision illustrate the consistent attention to vertical restraints.

Solace for companies seeking guidance on sustainability agreements

Now that the European Commission adopted the revised Horizontal Guidelines (HGs), including the new chapter on sustainability agreements, companies wishing to set up sustainability initiatives finally have more certainty on the applicable guidance.

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CBAM: current and future obligations for importers of certain carbon-intensive goods

The Carbon Border Adjustment Mechanism (CBAM) came into force on 1 October 2023. Importers of certain carbon-intensive goods have to report on emissions released during the production of those goods.

Lotte Paijmans

Junior Associate Amsterdam

Upper House Approval of Dutch 2024 Tax Package and certain other proposals

On Tuesday 19 December 2023 – exactly three months after publication – the Upper House of the Dutch parliament adopted the 2024 Tax Package (Pakket Belastingplan) including the 2024 Tax Plan (Belastingplan) and certain other proposals that were published.

From Farm to Fairness: Unpacking the Dutch Unfair Trading Practices Act for the Agri-Food Supply Chain

Since 2021, Dutch rules against unfair trading practices, which implemented an EU Directive, apply to business-to-business relationships in agri-food supply chains. Enforcement by the ACM, initially slow, is now intensifying.

Preventing environmental damage through sustainable cooperation

Following the EC’s Horizontal Guidelines, the ACM and CMA have also published updated guidance on sustainability agreements. The approaches adopted by the three authorities are largely similar, but leave room for divergent assessments in some respects.

EU Commission presents proposals for directives against shell entities and ensuring a global minimum level of taxation

On 22 December 2021 the European Commission (hereinafter: ‘EC’) presented two legislative proposals for EU directives, one to introduce a global minimum corporate tax rate and one to target EU shell entities. The key aspects of both proposals are discusse

Dominant firm may refuse to supply retailer after initial delivery

The Brussels Court of Appeal has held that a dominant producer firm may have valid reasons to refuse further supplies to a retailer, despite its dominance and despite previous deliveries.

Highest Dutch Court: ACM has not proved dominance of Dutch railway operator NS

A high market share is not always proof of a dominant position. The Trade and Industry Appeals Tribunal (CBb) upheld the annulment of the ACM’s fine of nearly EUR 41 million on Dutch railway operator NS for alleged abuse of dominance.

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