Another argument in favour of violating article 101, paragraph 1 of the FFP is that the way FFP regulates market behaviour and behaviour creates absolute territorial protection, which is contrary to Article 101, paragraph 1. The Court of Justice in fa Premier League/QC Leisure ruled that an agreement capable of re-establishing divisions between national markets should be regarded as an agreement to limit competition within the meaning of Article 101, paragraph 1, of the EUS. 156Case C-403/08, Football Ass`n Premier League v. QC Leisure, 2011 E.C.R.0000, para. 247. The FFP creates absolute territorial protection because the rules create market anchorage, which would restore the division of national markets. 377Mark Robben, Reports: UEFA to Devalue PSG deal, ESPNFC (April 30, 2014), www.espnfc.com/uefa-champions-league/story/1802680/reports-uefa-halves-value-of-paris-saint-germain-sponsorship-deal-with-qatar-tourism-authority. As noted above, FPFs have significant negative effects on competition. There are several exceptions to maintain agreements contrary to Article 101, paragraph 1. 259Ezrachi, supra note 115, at 53-54. Exceptions include exceptions to section 101, paragraph 3, a departure from the incidental restriction and the de minimis exemption.
260 d. Each of them is taken one after the other and is explained why they do not apply to FPFs. The cooperation agreement was extended on 21 February 2018 in the presence of Aleksander Eferin, First Vice-President of the European Commission Frans Timmermans and European Commissioner for Sport Tibor Navracsics. The new agreement outlined plans for close cooperation between the two organisations, with a focus on UEFA EURO 2020. The agreement also addressed other issues such as good governance, solidarity, integrity and other policies that influence the sustainable development of the game. UEFA can be seen as a business and not as a business association, because UEFA manufactures its own product – European football competitions -, controls national competitions and receives money from these measures. 300UEFA Champions League Revenue Distribution, Eur Union.