Vodafone has countered the government's assertion of a breakdown in talks over its tax dispute and said capital gains from the Hutchison transaction and a separate transfer pricing notice relate to the same deal and should be considered together for conciliation, reported PTI.
"The Vodafone India Services (VISPL) transfer pricing dispute on the alleged options transfer is entirely included within the dispute about tax on the Hutchison Essar sale," Vodafone said in a statement.
Vodafone said in seeking to tax the full value of the Hutchison Essar sale and then to claim tax on an alleged transfer of options in the Hutchison Essar sale, "the government is seeking to tax one event twice."
Vodafone said that it had entered into discussions with the Indian government in good faith, with a desire to achieve a fair outcome acceptable to both parties.
"Throughout, Vodafone has responded to the government's queries in a timely manner, notwithstanding, at one point, a six-month delay by the Indian government in responding to correspondence sent by Vodafone," the statement said.
Conciliation talks had broken down after Vodafone International Holdings BV issued a supplementary notice to the government, invoking the Bilateral Investment Promotion and Protection Agreement, and demanded that the transfer-pricing case be clubbed with the capital gains tax matter, said the PTI report.
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