Practical implications arising from the European Court's recent decisions concerning CFC legislation and dividend taxation

Dr. Simon Whitehead,Partner, Dorsey & Whitney, London

1. Introduction

Through a review of the Court's ruling in relation to controlled foreign company (CFC) legislation in C-196/04 Cadbury Schweppes plc v CIR and the approach to that decision in the United Kingdom, we will illustrate the new issues of practical difficulty presented by the European Court's recent case law for those practitioners and taxpayers to whom it now falls to apply the guidance of the Court in a national context.

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