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UK CFCs — the Way Forward

Stephen Edge of Slaughter and May makes some constructive suggestions on how the UK CFC regime should be conformed with EU fundamental freedoms
The Court of Appeal has always been a rather busy court aware of the fact that only difficult cases will come to it and that the most difficult will then go on for ultimate review by the House of Lords. It tends therefore to be a place where quick decisions are made.
Unfortunately swift despatch is not always what tax cases require. There are signs in one or two tax cases recently that the immediately visible and easy answer may have become too attractive an option.
Vodafone may have been one such case — but by opting...
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