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annul the applicant’s payslip for June 2021 and the note from the Commission’s HR Service of 14 June 2021 informing him that from 2021 onwards and following Brexit he would no longer receive the flat-rate sum for reimbursement of the costs of travelling to his place of origin;

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annul, in so far as it is deemed to supplement the statement of reasons for the contested decision, the decision of 22 December 2021 rejecting the complaint of 1 September 2021;

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order the defendant to pay the costs.

1.

First plea in law, claiming that the Staff Regulations of Officials of the European Union (‘the Staff Regulations’) should be applied teleologically and effectively and alleging that the administration made an error of law, that Article 7(4) of Annex VII to the Staff Regulations was infringed, and that the general implementing provisions on the place of origin infringe the Staff Regulations.

2.

Second plea in law, alleging infringement of the principle of equal treatment and unjustified discrimination, raising a plea of illegality and claiming that the provisions providing for the total abolition of reimbursement in the event of loss of citizenship should be disapplied.

3.

Third plea in law, in the alternative, first, claiming that the provisions at issue should be applied in accordance with the flexibility promised by the European Union regarding the interpretation of the Staff Regulations in a way that is generous to United Kingdom nationals and consistent with other internal rules and, second, alleging that the principle of compensation for the staff member’s expatriation status was infringed.