$2.6 Billion Tax Bill For Vodafone

The Bombay High Court ruled that Vodafone was liable for the tax after it acquired a 67 percent stake in the India telecom assets of Hong Kong’s Hutchison Telecommunications for $11 billion. Vodafone claimed it did not owe taxes because the trasaction was between two foreign entities — the Dutch subsidiary of the British telecom giant Vodafone and and CGP Investments Ltd., a Cayman Islands company which owned Hutchison’s Indian operations.

But the court ruled the transaction involved an Indian asset and was taxable.

The decision has ramifications on other major recent trasactions, including SABMiller’s acquisition of Foster’s Indian beer business, Aditya Burla Nuvo’s acquisition of shares in Idea Cellular from AT&T Mauritius and GE’s sale of its back office operations to Genpact.