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Controlled Foreign Companies

Ross Wilkinson and Warren Howells director and senior consultant respectively of Chiltern plc's corporate tax team analyse the Advocate-General's Opinion on the Cadbury Schweppes case at the ECJ
This is a highly significant tax case over which several hundreds of millions of pounds are at stake for HMRC in the UK. Following on the heels of the BAT (Test Claimants in the FII Group Litigation v CIR Case C-446/04) Opinion by the Advocate-General (A-G) it certainly provides numerous opportunities for companies to challenge current and prior filing positions. It will no doubt provide significant headaches for HMRC and other European fiscal authorities. The present case also affects other European Member States that have similar legislation aimed at counteracting perceived tax avoidance hence the unsurprising number of submissions from...

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