Court of Justice 21 January 2021, C-53/19 P and C-65/19 P (Banco Santander, SA and Others v European Commission.)

OPINION OF ADVOCATE GENERAL PITRUZZELLA delivered on 21 January 2021 ( 1 ) Joined Cases C‑53/19 P and C‑65/19 P Banco Santander, SA and Santusa Holding, SL v European Commission (C‑53/19 P) and Kingdom of Spain v Banco Santander, SA, Santusa Holding, SL, European Commission (C‑65/19 P) (Appeal – Corporate tax provisions allowing undertakings which are tax resident in Spain to amortise the