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A Structure Fit for Business

Rob Fleming Tax Executive for Vodafone looks at the key elements involved in operating the group structure to successfully meet the business' commercial needs
Operating even a relatively simple international holding and financing structure is a substantial task. The size of the task is not the result of trying to jump through loopholes in tax legislation as it is sometimes perceived — it is the result of executing genuine economic activities on arm's-length terms in a robust manner. This article focuses on the commercial drivers underlying the group structure and how the structure looks and works in practice.
Tax Environment
The tax environment has become increasingly challenging over the past decade. There have been negative and...

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