Speed Read: The ECJ X Holding BV decision on the Dutch tax consolidation rules is an interesting follow on to the Marks & Spencer decision on cross-border group relief. The High Court decision in the ACT GLO (classes 2 and 4) could have wider implications for Fokus Bank claims. The European Commission has announced proceedings against various Member States in relation to tax rules it considers are incompatible with EU law. There have been a number of 2010 budget announcements overseas in the Asia Pacific region and South Africa.