Kelly Stricklin-Coutinho

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note discusses the interaction between EU law, in particular the fundamental freedom of establishment, and the UK’s old controlled foreign company (CFC) regime, in particular discussing the impact of the Cadbury Schweppes, Vodafone 2 and CFC and Dividend GLO cases. This Practice Note was produced in partnership with Kelly Stricklin-Coutinho.

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note explains why EU law is relevant to the UK’s thin capitalisation and transfer pricing rules, in particular looking at the fundamental freedoms of establishment, movement of capital and movements of goods and services. It then goes on to explain the main elements in the first major EU case on thin capitalisation, Lankhorst-Hohorst, and the UK’s group litigation order on the questions that followed (the Thin Cap GLO). This Practice Note was produced in partnership with Kelly Stricklin-Coutinho.