The Business Law Reports
[2009] Bus LR 96
Chancery Division
Vodafone 2
v
Revenue and Customs Commissioners
[2008] EWHC 1569 (Ch)
2008 May 20–
22;
July 4
July 4
Evans-Lombe J
Revenue— Corporation tax— Controlled foreign company— Profits of controlled foreign companies apportioned among parent companies and taxed in their hands— Exception where main purpose of controlled companies not reduction of UK tax— Whether apportionment confined to artificial arrangements— Whether compatible with right to freedom of establishment—
Income and Corporation Taxes Act 1988 (c 1), ss 747(3), 748(3) (as amended by Finance Act 1998 (c 36), s 113, Sch 17, paras 1(3), 3(7)(8))
—
EC Treaty
, art 43EC