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annul Commission Decision C(2020) 8550 final of 4 December 2020 on aid scheme SA.21259 (2018/C) (ex 2018/NN) implemented by Portugal for Zona Franca da Madeira (ZFM) — Regime III;

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order the Commission to pay the costs.

1.

First plea in law, alleging an error of assessment regarding fulfilment of the requirements for the compatibility of the aid scheme Zona Franca da Madeira — Regime III (‘ZFM’), in particular as regards the origin of the profits and the creation and maintenance of jobs in the region.

2.

Second plea in law, alleging undue delay on the part of the Commission in amending the successive versions of the ZFM scheme as regards the criterion for calculating the number of jobs created/maintained.

3.

Third plea in law, alleging infringement of the obligation to state reasons, in so far as the decision adopted is not sufficiently reasoned as regards the meaning of ZFM jobs and as regards the activity effectively and materially performed in Madeira.

4.

Fourth plea in law, alleging infringement of the right to a fair trial and of the principle of equality of arms, due to the delay on the part of the Commission in correcting parts of the ZFM legal framework and the short time limit allowed for the applicant to exercise its rights of defence.

5.

Fifth plea in law, alleging infringement of legitimate expectations, due to the delayed action on the part of the Commission and the content of the contested decision.

6.

Sixth plea in law, alleging infringement of the principle of legal certainty, due to the delayed action on the part of the Commission and the amendment of the State aid scheme in place for a certain regulatory period.