Vodafone 2 was refused leave to appeal to the Supreme Court in its CFC case.
Unsurprisingly Vodafone 2 have been refused leave to appeal to the Supreme Court.
In March 2007, the ECJ concluded that the UK’s Thin Cap rules would offend Community law unless they could be interpreted as applying only to wholly artificial arrangements designed to obtain a tax advantage and protected genuine commercial arrangements from any thin cap adjustments even if beyond arm’s length terms.
In July 2008, we reported on the High Court decision in the Vodafone 2 case.
The High Court hearing in the Thin Cap Group Litigation concluded on 30 January.