A key issue behind the UK’s CFC reform has been the need to ensure that the new regime is compliant with EU law. A particular area of difficulty is the application of the regime to non-UK group finance companies. Looking around Europe, following the Cadbury Schweppes decision, most countries have taken steps in an attempt to make their regimes EU compliant, but a closer examination of these other regimes, and their application to a specific example, demonstrates that the UK is not alone in struggling to craft an EU compliant CFC regime.
