Vodafone tax deal over Irish subsidiary

Vodafone has made a previously unreported multi-million pound settlement with HMRC over disputed tax claims at an Irish subsidiary created to collect royalty payments for using its brand.

The UK-based mobile phone group is reported to have used Vodafone Ireland Marketing Ltd, which employed no staff between 2002 and 2007, to collect hundreds of millions of pounds a year in royalty payments from operating companies and joint ventures around the world, according to an investigation by the Guardian.

The subsidiary company was also allegedly used to send more than €1bn (£852m) worth of dividends to the low-tax jurisdiction of Luxembourg during this period, while Vodafone also reportedly moved senior marketing managers to Dublin to avoid paying UK tax on revenues from global royalties and take advantage of lower corporation tax rates.

The Guardian's report claims that accounts filed in Dublin show that in 2009, HMRC settled a dispute with Vodafone over its Irish tax returns. The size of the settlement has not been revealed, but it involved Vodafone reclaiming €67m (£57m) from the Irish government in tax that should have been paid in the UK.

According to the paper, the company confirmed its Irish settlement had never been separately disclosed in its annual reports, and was not connected to a £1.25bn (£1.07bn) payment to HMRC in 2010 to settle a high profile dispute over the use of a Luxembourg subsidiary.

An HMRC spokesman said the department was prevented by law from discussing the affairs of individual taxpayers and refused to confirm whether any settlement over Vodafone's Irish tax affairs had been made.

Pat Sweet | Reporter, Accountancy Daily [2010-2021]

Pat Sweet was the former online reporter at Accountancy Daily and contributor to the monthly Accountancy magazine, pub...

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