According to Irish news outfit RTE, if successful, it could force the European Commission to review the ruling against Ireland for its tax treatment of Apple.

Fiat Chrysler was ordered to pay €30m in back-taxes to Luxembourg following a crackdown by European Commission anti-trust regulators into illegal subsidies. In 2015, it concluded that the taxable profits for Fiat's Luxembourg unit could have been 20 times higher under normal market conditions and ruled that the agreement between Luxembourg and the firm in 2012 constituted illegal state aid. An earlier appeal to the EU General Court confirmed the European Commission’s findings.

The action by Ireland’s finance department comes as Fiat Chrysler also lodged an appeal with the Court of Justice of the European Union on 4 December 2019. Ireland’s finance department appears to have lodged its appeal on the same day, according to the European Journal.

Among its main arguments, Ireland pleads that the General Court breached articles and “impermissibly used the State aid rules to harmonise Member States’ direct taxation rules.”

According to RTE, specific points in the Fiat ruling could have a bearing on the European Commission’s finding that Ireland provided illegal state aid to Apple. The Commission ordered Ireland to collect €13b in unpaid taxes from Apple.

The CJEU reportedly takes around 18 months to respond to appeals.