The uncertain future of CFC regimes in the member states of the European Union - part 2

Part 1 of this article dealt with general aspects of controlled foreign company (CFC) regimes with particular reference to domestic law and tax treaties. In Part 2, the author considers the compatibility of CFC regimes and the fundamental freedoms protected under the EC Treaty and finds guidance in the evolution of European Court of Justice case law. The author concludes by summarizing the arguments and observations presented in Parts 1 and 2.