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Mr Brown's Final Autumn Statement?

The Tax Journal brings you extracts from Ernst & Young's commentary on the Pre-Budget Report of 6 December 2006

 
The Tax Journal brings you extracts from Ernst & Young's commentary on the Pre-Budget Report of 6 December 2006
CFC Changes — New EU/EEA Exemption — Put In Caps
 
The PBR introduces proposed amendments to the controlled foreign companies (CFC) legislation following the European Court of Justice's (ECJ) decision in Cadbury Schweppes C-196/04. In that case the ECJ held that the UK's CFC rules are in general terms consistent with the EC Treaty but are precluded by the EC Treaty to the extent they apply to companies established in an EU or European Economic Area (EEA) territory carrying on activities that are...

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