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Vodafone 2

Chris Morgan Kit Dickson and Sarah Anderson from KPMG's International Tax Services team take us through the recent Court of Appeal decision in the Vodafone 2 case
On 22 May 2009 four years to the month after the Special Commissioners first referred the case to the ECJ the Court of Appeal handed down its decision in Vodafone 2 [2009] EWCA Civ 446. The case concerned the application of the UK's CFC legislation (ICTA 1988 ss 747 et seq) to a finance company which was resident in Luxembourg. Observers will have been waiting to see whether the Court of Appeal confirmed the decision of the High Court that the CFC rules should be completely disapplied in an EU context. If so the implications for CFCs and other EU...
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