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Love the hogwash preamble about participating in the single digital market. Vodafone has several large operating companies already active in Europe so this is not an issue. The real issue is the taxation of profits that have not yet been distributed to the UK, sitting in its European subsidiaries. The UK lost a case in the ECJ where it tried to apply the UK's CFC (controlled foreign corporation) tax rules taxing passive income in subsidiaries in low tax countries (in this case Luxembourg). The ECJ ruled that this was against various EU principles. After Brexit, all gloves are off and firms such as Vodafone risk a big tax bill. While we are still in the EU, they may be able to get away with a corprate restructuring that largely avoids any exit charges, but that may rely on having a business purpose and not just being some fancy footwork with their tax bill. Hence the guff about single digital markets.