18 September 2006
Categories:
Tax cases
What motive?
Cadbury Schweppes had two subsidiaries resident in the Republic of Ireland, which were subject to a 10% rate of tax. HMRC said that the controlled foreign companies legislation applied under TA 1988, ss 747 to 756. The company appealed, saying that this breached Articles 43EC, 49EC and 56EC of the EC Treaty (freedom of establishment).
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