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Competition and State Aid Implications of the Spezzino Judgment (C-113/13): the Scope for Inconsistency in Aid Assessments for Voluntary Organisations providing Public Services

Albert Sánchez-Graells


This paper assesses the competition law and State aid implications of the CJEU Judgment in Azienda sanitaria locale n. 5 "Spezzino" and Others (C-113/13 [2014] ECLI-2440). It pays particular attention to the departure from the Altmark test for the assessment of public support granted to providers of public services as well as to the change of mind by the CJEU regarding the special position of non-profit entities in the direct award of public service contracts.

Senior Lecturer in Law, University of Bristol Law School. A previous version of this article has appeared at Social Science Research Network.

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