There was a further update document and revised draft legislation on CFC reform published at the end of February. The Court of Appeal has upheld the previous Tribunal decisions in favour of the taxpayer in the First Nationwide case on a tax planning scheme to create tax deductions involving the manufactured overseas dividend rules. The European Commission has published a consultation on factual examples and possible ways to tackle double non-taxation cases. A Green Paper has been published by the French and German Ministries of Finance on the subject of German-French co-operation in the area of business taxation.
