The reviews are being put in place in response to requirements from the European Union, following a landmark ruling by the European Court of Justice last year involving Cadbury Schweppes.
The Cadbury Schweppes case focused on tax arrangements established in Ireland and questioned whether these arrangements were ‘artificial’ and only put in place to get around the UK tax law.
The European court concluded that the current UK tax rules required amendment in order to comply with European standards.
Her Majesty’s Revenue and Customs in the UK have announced a review this month of the UK taxation of foreign profits, including a major overhaul of the CFC regime, and have issued a discussion paper.
