In the Press
June 4, 2025

EU Telecom Merger Ruling Unveils Foreign Subsidies Analysis (Law360)

Partner Stephen Mavroghenis and associate Hyunseok Doh write for Law360 that on April 4, the European Commission published the full, nonconfidential version of its decision concerning Emirates Telecommunications Group Co.'s acquisition of PPF Telecom Group BV's telecommunications businesses in Bulgaria, Hungary, Serbia and Slovakia. This transaction represents the first clearance with commitments under the European Union's Foreign Subsidies Regulation. Importantly, the publication of the decision provides the first detailed insight into the commission's analytical approach and procedural expectations under the FSR, thereby offering valuable guidance on how future foreign subsidies investigations — particularly those involving state-owned enterprises and sovereign wealth funds — are likely to be conducted and assessed. The case provides a comprehensive overview of how the commission will assess foreign financial contributions, identify distortive subsidies, and enforce behavioral commitments.

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