Skip to content
Tuesday 11 August 2026London --:--Frankfurt --:--Zurich --:--
NewslettersSearchEN · DE
MorningWire

European business, markets and politics

FTSE 100
10,844.19
-0.17%
DAX
26,391.42
+0.26%
CAC 40
8,714.94
-0.13%
STOXX 50
6,551.22
+0.24%
  • Europe
  • Markets
  • Business
  • Economy
  • Technology
  • Politics
  • Opinion
More
GermanyFranceBankingAIEnergyFintechPropertyCapital Markets
  • Germany
  • France
  • Europe
  • Markets
  • Business
  • Economy
  • Technology
  • Politics
  • Opinion
  • DE
Tuesday 03 September 2013 8:47 pm

Vodafone isn’t avoiding UK tax on the sale of its stake in Verizon Wireless

By: Express KCS

Add as a preferred source on Google

THE screams of rage, as the statists realise they’re not going to get any money from the sale of Vodafone’s stake in Verizon Wireless, have become deafening. We’ve even seen UKUncut insist quite seriously that £84bn of tax is being avoided (£84bn is the total transaction size, not the profit or the tax). But the simple truth is that no tax is going to be paid to the UK Treasury because no tax is due to the UK Treasury.

The boring details are that the shares in the US company, Verizon Wireless, are held in a US company. This is, in turn, owned by a Dutch subsidiary of Vodafone. That US company will (with a couple of minor complications) be sold to Verizon in return for shares and cash. Under both US and Dutch law, this transaction incurs no tax bill.

It used to be true that, under the controlled foreign companies regulations here in the UK, there could potentially be a UK tax bill. But that had the kibosh put on it by the EU in the Cadbury case. And this is what that previous kerfuffle over Vodafone’s taxes was all about – that mythical £6bn that had Private Eye up in arms.

It also used to be true that, if and when Vodafone tried to bring that money from Holland to the UK, it would have had to pay corporation tax before it could pay it out as a dividend. This is what that supposed “settlement” with HMRC chief Dave Hartnett was all about in the earlier £6bn case. Then, Vodafone’s money in Luxembourg was not subject to UK tax, but the amount it brought into the UK was: so when it moved it to Britain to pay the dividend it was taxed.

That was changed under the 2009 Corporation Tax Act (CTA), and such dividends brought in from a subsidiary abroad are now not taxed in the UK. Thus, at the corporate level, there is no tax bill in the Vodafone-Verizon deal: it is just the shareholders who will pay on the special distribution of the dividend.

All of this makes sense: there is really one economic transaction here, and it will be taxed once, at the level of the shareholders – the people who are going to get most of the money.

We could whine that, as this is being done through Holland, there must be dirty dealings. But in 2002, the Finance Act changed UK law so that, even without that Dutch step, the result would be exactly the same. The substantial shareholdings exemption (SSE), which was famously used by The Guardian when offloading half of AutoTrader, brings UK law in line with that of other European countries including Holland. Thus, this is not some avoidance trick using offshore and secrecy jurisdictions. This is the clear meaning and intent of current UK law: not taxing Vodafone here is in line with both the letter and spirit of the law.

It is the 2009 CTA which means that no tax is to be paid by Vodafone on the dividend. And even without the Dutch step, the 2002 Finance Act would ensure none is due. But I have one wish: could the next person who interviews Margaret Hodge MP on this issue please record her answer to the point that she voted for both the 2002 Finance Act and the 2009 CTA?

Tim Worstall is senior fellow of the Adam Smith Institute, and author of Chasing Rainbows: Economic Myths, Environmental Facts.

Share this article

  • Facebook
  • X
  • LinkedIn
  • WhatsApp
  • Email

Similarly tagged content:

Sections

  • Opinion

Categories

  • Opinion

Related Topics

  • Verizon

Trending Articles

  • Five-star Mayfair hotel hit with HMRC winding-up petition

  • Nottingham Forest owner Marinakis sues Crystal Palace for defamation

  • Back to basics: Sainsbury’s gradual retreat from the British high street

  • Hargreaves Lansdown orders staff back to office

  • As it happened: Intel, Arm shares slide; Oil climbs higher

More from Morning Wire

  • BT braces for loss of 800,000 customers as it banks on fibre to keep turnaround ‘on track’

    Telecoms
    A sign at the headquarters building of BT Group Plc in Aldgate, (Photographer: Hollie Adams/Bloomberg via Getty Images)
  • Vodafone shares jump as French telecoms tycoon becomes top shareholder

    Telecoms
    Vodafone Group has announced the appointment of Microsoft's Pilar López as its new chief financial officer.
  • Burnham tax plans spark investor rush to bank capital gains

    Tax
    Andy Burnham discussing capital gains tax increase during a press conference, highlighting potential economic impacts
  • IHT pension scramble shows ‘no sign of slowing down’, says Royal London boss 

    Investing
    Royal London shared £181mn with its 2.3m customers in April
  • Lucy Rigby back as City minister

    Politics
    Lucy Rigby, a blonde woman in glasses and a red blazer, with a phone in her pocket, walking past a black gate.
  • Ban foreign stocks from Isa wrapper, says top pensions boss

    Investing
    Nicholas Lyons, former Lord Mayor of London, speaking at a podium with microphones, discussing fresh ISA rules.
  • Tom Kerridge: No good restaurant has ever been run by accountants

    Hospitality
    Celebrity chef Tom Kerridge smiling during a cooking demonstration, wearing a chefs uniform in a professional kitchen setting
  • The Rest Is… for the Treasury: Gary Lineker backs wealth tax for rich

    Sport Business
    Gary Lineker in a suit and tie, smiling with glasses and a goatee, against a blurred background.
MorningWire

Independent European business, markets and political news for decision-makers.

Morning Briefing

Europe

  • Germany
  • France
  • Europe
  • UK & Ireland

Business

  • Markets
  • Banking
  • Technology
  • Energy
  • Property
  • Fintech

Editorial

  • Opinion
  • Editorial Policy
  • Corrections
  • Contact

Company

  • About Morning Wire
  • Privacy Policy
  • Terms of Use
  • Cookie Policy
© 2026 Morning Wire Ltd · Published by Morning Wire Media, Bahnhofstrasse 65, 8001 Zürich, Switzerland
Privacy · Terms · Cookies · Facebook