Judgment of the Court (Second Chamber) of 15 September 2022.#Fossil (Gibraltar) Limited v Commissioner of Income Tax.#Request for a preliminary ruling from the Income Tax Tribunal of Gibraltar (Royaume-Uni).#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.#Case C-705/20.