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Introduction The compliance and operating costs resulting from twenty-seven different private limited liability company regimes throughout the European Union makes the operation of foreign subsidiaries of SMEs considerably more expensive than domestic subsidiaries. [...] EU SMEs that exercise their freedom of estabUshment rights (e.g., by incorporating as a UK private limited liability company while maintaining their central administrative office in another Member State), probably encounter a degree of distrust from creditors and banks. Finally, some modifications of the Corporation Tax Law, approved by the Royal Decree Law 4/2004 of March 5,74 are made in order to adapt its provisions to the new accounting framework.

Some significant changes proposed in the review should already be familiar to U.S. companies: direct liability of manufacturers throughout the E.U. for non-conforming goods;16 and placing the burden of proof on the seller of a product to prove that it was not defective at the time of delivery under the rationale that the seller is more likely to possess the relevant information to make such a showing.17 B. CONSUMER REDRESS On April 4, 2007, the Commission published the results of a year-long study on \"[a]n analysis and evaluation of alternative means of consumer redress other than redress through ordinary judicial proceedings,\"18 which reviewed the means available in each E.U. member state to resolve consumer disputes, including collective action proceedings.