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" ... To get more into the court's reasoning though, it backed its decision on the matter based on the nonapplication of Luxembourg's abusive law provisions. The court reason that Engie is similarly situated to other Luxembourg taxpayers that cannot benefit from the nonapplication of the antiabuse provision. Luxembourg should've applied its general antiabuse rule to reject the ruling request, but it didn't. So that alone seems to result in a clear selective advantage for Engie. They found that the insanely wacky financing structure resulted in a reduction in the corporate tax rate that would have been payable by other similarly situated taxpayers. ... "