• conditions for “controlled foreign company”:
    • more than 50% of capital control, voting rights, profit entitlement
    • less than 50% taxed of parent company
    • more than 1/3 of subsidiary is passive
  • Effect: CFC is taxed as if parent made profit
    • no need for dividend distribution
  • exemption: valid commercial reasons
    • Cadbury Schweppes carve out for “genuine economic activities”
    • respect EU fundamental freedoms (freedom of establishment)