Roopa Aitken International Tax Partner Grant Thornton comments on the Vodafone 2 High Court victory
The High court judgment in the Vodafone 2 case1 was delivered on 4 July 2008. The case which concerns the compatibility of the UK's controlled foreign companies (CFCs) legislation with EU law provides a convincing victory for Vodafone and overturns the decision of the Special Commissioners. This is an important case in the UK as it has potentially wide implications both for UK multinationals and also the ongoing consultation concerning the taxation of foreign profits.
CFC legislative background
In broad terms a UK-tax-resident company is subject to corporation tax on its worldwide profits including those...
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Roopa Aitken International Tax Partner Grant Thornton comments on the Vodafone 2 High Court victory
The High court judgment in the Vodafone 2 case1 was delivered on 4 July 2008. The case which concerns the compatibility of the UK's controlled foreign companies (CFCs) legislation with EU law provides a convincing victory for Vodafone and overturns the decision of the Special Commissioners. This is an important case in the UK as it has potentially wide implications both for UK multinationals and also the ongoing consultation concerning the taxation of foreign profits.
CFC legislative background
In broad terms a UK-tax-resident company is subject to corporation tax on its worldwide profits including those...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")