Hamit Sari discusses domestic time limits on loss carry-forward and cross-border loss relief
Cross-border loss relief at Community level continues to attract overwhelming attention and has been at the very centre of the debate on taxation in the Community in particular since the Marks & Spencer judgment of the ECJ1. Having regard to the fact that the Commission's efforts to introduce a Directive have failed in the past and its work on a common consolidated corporate tax base (CCCTB) have not been finalised yet the compatibility of national provisions on cross-border loss relief with Community law specifically with the fundamental Community freedoms is assessed by the Court and some general principles can be deduced from its rulings.
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Hamit Sari discusses domestic time limits on loss carry-forward and cross-border loss relief
Cross-border loss relief at Community level continues to attract overwhelming attention and has been at the very centre of the debate on taxation in the Community in particular since the Marks & Spencer judgment of the ECJ1. Having regard to the fact that the Commission's efforts to introduce a Directive have failed in the past and its work on a common consolidated corporate tax base (CCCTB) have not been finalised yet the compatibility of national provisions on cross-border loss relief with Community law specifically with the fundamental Community freedoms is assessed by the Court and some general principles can be deduced from its rulings.
This article due to the limited space available does...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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