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Europe Daily Bulletin No. 9263

13 September 2006
Contents Publication in full By article 27 / 34
GENERAL NEWS / (eu) eu/court of justice
UK legislation on controlled foreign companies can only apply to wholly artificial tax arrangements

Luxembourg, 12/09/2006 (Agence Europe) - In its Cadbury Schweppes ruling, the European Court of Justice notes that UK legislation on what are known as 'controlled foreign companies' (CFCs) can only apply to wholly artificial tax arrangements. In order to determine whether a CFC is carrying on a genuine activity, the natoinal authorities should take account of objective factors which are obtainable by third parties, and not only subjective considerations, explains the Court of Justice in a...

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