I've done several posts related to the Canada - Renewable Energy AB reasoning on "benefit." As I noted, there is some uncertainty as to the potential scope of the ruling. How much leeway do governments now have to provide finanical contributions in a way that "creates a market" without leading to a finding of "benefit"? It will take some more cases to work this all out.
This may come through WTO subsidy disputes, of course. But perhaps the developments will also come through CVD cases? There are more CVD cases than WTO subsidy cases. Will respondents and their governments try to come up with creative arguments in CVD proceedings to the effect that the financial contributions at issue do not result in a "benefit" under the AB's Renewable Energy reasoning, and thus do not constitute a subsidy? It seems like it's worth a shot. Perhaps this will provide the first opportunity to explore the AB's reasoning.