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Rules definition

What does Rules mean? Rules describes the written provisions that govern how a pension scheme operates—especially occupational pension schemes—usually contained in, or annexed to, the trust deed (trust deed and rules). Legislation refers to these as scheme rules (for example, Pensions Act 1995 and Pensions Act 2004 in the UK, and the Pensions Act 1990 in Ireland). Scheme rules set out eligibility, benefit structure (defined benefit or defined contribution), contributions, service and accrual, retirement options and ages, revaluation/indexation, ill‑health and death benefits, transfers in and out, leaver provisions, forfeiture, augmentation, priority on winding‑up, discretions and decision‑making, and the scheme’s amendment and termination powers. They also...

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EU compatibility of the UK CFC regime: Cadbury Schweppes, Vodafone 2, CFC and Dividend GLO, and the 2006–2013 reforms

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Practice notes
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ARCHIVED: This Practice Note has been archived and is not maintained.

This Practice Note sets out:

  • the overarching concept of controlled foreign company (CFC) Rules
  • the UK’s CFC regime before its reform (ie from 2013)
  • the application of EU rules to the UK’s CFC regime via the cases of Cadbury Schweppes, Vodafone 2 and the CFC and dividend GLO
  • how EU principles could apply to the UK’s new CFC rules

What are controlled foreign company rules?

CFC rules are Anti-avoidance measures adopted by countries concerned that domestic companies might artificially move Profits to companies situated in low-tax jurisdictions...

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Kelly Stricklin-Coutinho
Kelly Stricklin-Coutinho chambers

Kelly specialises in International Tax Planning, Direct Tax, Tax litigation and enquiries, EU Law, Remedies in Tax Disputes and Commercial Litigation.   ...

Web page updated on 21/05/2026

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