International Tax Report

This article is divided into two parts. In Part I, Richard Wellens examines the background to the United Kingdom’s CFC regime, the Cadbury Schweppes [1] case and the response of the UK government to the decision of the ECJ. In Part II, which will be published next month, the Vodafone 2 [2] case is analysed and recent changes to the United Kingdom’s CFC regime are examined for compatibility with Community law.

Ilya Rybalkin, Partner, Hogan & Hartson (Moscow), Vadim Kukushkin, Senior Advisor, Hogan & Hartson (Moscow), and Ivan Meleshenko, Associate, Hogan & Hartson (Moscow)