“…nz eG v Finanzamt Köln-Mitte [2007] ECR I-2647, and other early cases such as Case C-196/04 Cadbury Schweppes plc v Commissioners of Inland Revenue ECR I-7995, [2007] Ch. 30 referred to the balancing of taxing powers as a combination of three elements; the preservation of the allocation of the power to impose taxes together with th…”
“…due on the profits generated by activities carried out on national territory”: Case C-196/04 Cadbury Schweppes plc v Inland Revenue Commissioners EU:C:2006:544;[2007] Ch 30, [55]. In the present context, however, the UK has not sought to impose any restriction on the freedom of establishment of the participating companies, so one …”