We Would Like to Ask for a Clarification Regarding the Interpretation of Article 4(3)(B)

We would like to ask for a clarification regarding the interpretation of Article 4(3)(b) of De minimisaid Regulation 1407/2013.

Article 4(3)(b)provides the condition under which loans secured by collateral covering at least 50 % of the loan could be given to healthy companies without calculating theGGE on the basis of the reference rate applicable at the time of the grant:

(b) the loan amounts to either EUR 1 000 000 over 5 years or EUR 500 000 over 10 years; if a loan is for less than those amounts and/or is granted for a period of less than five or 10 years respectively, the GGE shall be calculated as a corresponding proportion of EUR 200000 de minimisceiling.

1)It is not clearwhether EUR 1000000 for loan with less than 5 years duration is the absolute maximum or the amount may be increased depending on the duration. For example,if thecompany applies fora loanof EUR1 MEURfor 1 year, then theloan is accompanied byGGE lowerthande minimisaidceiling. So could the company in this case apply also for 2 MEUR or bigger loan, depending on how big is itsfreede minimislimit?

Reply: No. Thelimitsindicated (budget and duration) are themaximumlimits. Thegrantormaychooselowervaluesbutnothigherones (e,g, thecompanytakes a loan of 1 Miofor 1 yearwith a GGE of 40,000 Euro). Ifbudgetisstillavailable and theceillingisnotexceeded, thenextyear, thecompanycouldbenefitagain of a loan of 1 Miofor a periood of 1 year.

2)Is it possible to extend a loan in case where after getting a loan thecompany'sde minimisaidthresholdreaches EUR 200000?

Reply: Onceanundertakinghasreceivedde minimisaid of 200,000 Euro over a threeyear periood, no additionalde minimisaidmaybegrantedtothatundertaking (inanyform, inlcudingloansorguarantees).