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Esso Exploration and Production UK Ltd and others v HMRC

In Esso Exploration and Production UK Ltd and others v HMRC [2020] UKFTT 139 (TC) (4 March) the FTT rejected a claim for group relief by seven UK companies in respect of losses of £228m incurred by a Danish company in the same worldwide group.  

Esso and the other appellant companies were all UK-resident and for the accounting periods ended 31 December 2001 2002 and 2003 they claimed group relief for losses incurred by a Danish-resident company EMDH. The only link between EMDH and the appellants was that their ultimate parent was a US corporation  EMC. EMDH’s immediate parent was a company resident in Luxembourg. In 2012 the business of EMDH was transferred to a Danish permanent establishment of a Norwegian group member (N) and the company was liquidated in 2013 thereby extinguishing all of its losses.  

It was agreed between the parties that under the UK law then in force the only exception to the...

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