115The Commission stated in Article 1 of the contested decision that three of the five tax measures which in its view make up the STL system constituted State aid ‘to the EIGs and their investors’. The measures in question are early depreciation (measure 2) and the application of the tonnage tax scheme (measure 4), as clarified in Article 50(3) RIS (measure 5). Article 4(1) of the contested decision provides, however, that the Kingdom of Spain is to recover the incompatible aid granted under the scheme referred to in Article 1 ‘from the EIG investors that have benefited from it, without the possibility for such recipients to transfer the burden of recovery to other persons’.
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