Market leading insight for tax experts
View online issue

PBR 2006: CFCs — Must Try Harder!

Sara Luder of Slaughter and May looks in some more detail at the CFC changes announced in the Pre-Budget Report 2006
Stephen Edge gave his initial reaction to the PBR CFC changes in The Tax Journal Issue 866 18 December 2006. This article looks in some more detail at the proposed changes and considers whether they now bring the UK's CFC legislation into line with EU law.
In Cadbury Schweppes the ECJ held that the UK CFC legislation did amount to a hindrance to the freedom of establishment contrary to Article 43 of the EC Treaty. But the ECJ also held that it was necessary to go on to consider whether the CFC rules were nonetheless justified.
What might...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.