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UK CFC Regime

Stephen Edge Slaughter & May looks at the opportunity for HMRC and industry to make the CFC rules both EU-compliant and fair and stable
Every lawyer has been there. You spend ages drafting a document to cover all conceivable eventualities and then the thing that happens is the one thing nobody predicted. A lot of undignified scrambling results as you try to squeeze the facts of what has happened into the description of all the other things that you thought might happen (but haven't) in order to give your client a remedy.
HMRC's brave attempt to do that with the CFC rules drafted at a time when we were trying to pretend that we were not in Europe foundered on the rock of the Vodafone 2 case when an...

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