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Tax Case News

Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases gives us the latest tax case news
HMRC v Vodafone 2 (CA – 22 May)
The CA has allowed HMRC's appeal against the Ch D decision reported at [2008] STC 2391. HMRC formed the opinion that a company (V) which had established a subsidiary company in Luxembourg was liable to tax under the 'controlled foreign companies' (CFCs) legislation of ICTA 1988 ss 747 to 756. HMRC issued a notice of enquiry under FA 1998 Sch 18 para 24. V subsequently applied to the Special Commissioners for a direction under Sch 18 para 33 contending that the notice...

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