Cadbury Schweppes vs UK: JUDGMENT

Case Information

  • Court: Court of Justice of the European Union (Grand Chamber)
  • Case No: C-196/04
  • Applicant: Cadbury Schweppes plc and Cadbury Schweppes Overseas Ltd
  • Defendant: Commissioners of Inland Revenue
  • Judgment Date: 12 September 2006

The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States’ tax authorities to impose tax measures on Controlled Foreign Companies (CFCs). The key issue in this case was whether the UK’s CFC legislation, which sought to include the profits of foreign subsidiaries (CFCs) in the tax base of their UK parent company, violated the freedom of establishment under the EU Treaty.

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File Type: pdf
File Size: 258 KB
Countries: European Union, United Kingdom
Tags: CFC, EU Tax, Freedom of Establishment, Tax Compliance, Transfer Pricing