Speedy tax resolution unlikely for Vodafone

Abstract

Vodafone's battle with the taxman over its Mannesmann tax arrangements looks set to drag on. Court papers on the case make clear that it concerns the L112 billion deal to take over the German mobile group Mannesmann, sealed in 2000. Vodafone Investments Luxembourg, into which shares in Mannesmann were moved, was subject to the 'motive test' and so outside UK CFC rules, Vodafone had said, while the German firm, Vodafone Deutschland, met the 'exempt activities' test.