Second, the statement doesn’t note that Vodafone fought this for nine years and lost all the way.
No, they didn\’t.
They won all the way to the Court of Appeal.
They won at the Special Commissioners, they won in the High Court.
The essential question was: Do the CFC rules apply to EU subsidiaries?
Special Commissioners said \”No\”. High Court said \”No\”.
Court of Appeal said \”maybe\”.
And how do we know that Vodafone won? Because it was HMRC that appealed the two junior decisions.
Anyone and everyone is allowed their own opinions on whether CFC should or should not apply. But no one is allowed their own facts.
And we get a response!
@worstall I don\’t do lying….they lost because the courts denied them the right to appeal their loss – that\’s losing all the way I think