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Clifford Chance LLP

We are one of the world's leading law firms, operating across five continents.

Lobbying Activity

Meeting with Emanuele Tarantino (Chief Economist Competition), Thomas Kramler (Head of Unit Competition)

30 Sept 2025 · Presentation of a proposed framework for the assessment of FRAND access terms for app stores in the context of the DMA. Other interest representative Compass Lexecon.

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Fleishman-Hillard and Structured Finance Industry Group, Inc., d/b/a Structured Finance Association

15 Sept 2025 · Securitisation

Response to Foreign Subsidies Guidelines

2 Apr 2025

Clifford Chance welcomes the opportunity to respond to the call for evidence by the European Commission (EC) regarding the EU Foreign Subsidies Regulation (FSR). Our observations below are based on our experience advising on FSR proceedings and compliance. However, the comments in this response do not necessarily represent the views of every Clifford Chance lawyer, nor do they purport to represent the views of our clients. Further clarifications are required on the distortion of competition test for concentrations, regarding the evidence required to establish that a foreign subsidy would not distort the acquisition process or have post-transaction effects on competition (and whether future subsidies are relevant to the latter assessment), as well as the relative importance of the factors taken into account. See section 1 of the attachment for an explanation of these points. The EC's guidance should use EU State aid rules as a basis for the balancing test, as adjusted for FSR purposes. In particular, specific types of subsidies meeting certain thresholds should be deemed as having positive effects outweighing any negative effects, while the balancing test should be conducted on the basis of market characteristics. Moreover, the guidance should explain how positive effects outside of the EU will be taken into consideration in this balancing test. See section 2 of the attachment for an explanation of these points. The Commission's intention to clarify which criteria will be considered when deciding whether to call-in below threshold mergers and public tenders, is welcomed and various suggestions for issues that should be covered by such guidance are included in the attachment. See section 3 of the attachment for an explanation of these points. There should be a Short Form notification form, with Simplified Procedures for unproblematic cases, based on EC's experience so far, e.g. for transactions involving private equity investors which only exceed the filing threshold due to commitments by passive LP investors. Simplified forms should include further exemptions (e.g., to provide information on FFCs only for the last year or exceeding the threshold of FFCs within the respective third / non-EU countries). See section 4 of the attachment for an explanation of these points.
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Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen)

4 Feb 2025 · GREGY project

Meeting with Stella Kaltsouni (Cabinet of Commissioner Dan Jørgensen) and ELICA MEDITERRANEAN ELECTRICAL INTERCONNECTION SINGLE MEMBER SA (COPELOUZOS GROUP)

4 Feb 2025 · GREGY project

Response to Enhancing the convergence of insolvency laws

17 Mar 2023

Please see attachment.
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Response to Detailed procedures for addressing distortive foreign subsidies

6 Mar 2023

Please see the attached response of Clifford Chance LLP to the consultation on the Draft Implementing Regulation for the Foreign Subsidies Regulation
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Response to DMA Implementing Regulation

9 Jan 2023

Please see the attached response from Clifford Chance LLP to the consultation on the Draft DMA Implementing Regulation and related documents.
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