Chris Morgan, Head of KPMG's EU Tax Group, and Jonathan Bridges, of KPMG's EU Tax Group, comment on the A-G's Opinion delivered in Oy AA Case C-231/05
Chris Morgan Head of KPMG's EU Tax Group and Jonathan Bridges of KPMG's EU Tax Group comment on the A-G's Opinion delivered in Oy AA Case C-231/05
On 12 September 2006 Advocate-General (A-G) Kokott delivered her Opinion in the Oy AA case. The case considers whether a profitable Finnish company should be entitled to relieve its profits against overseas group company losses. With the European Court of Justice (ECJ) having recently established a cross-border profit-loss offset principle in M&S Case C-446-03 the Oy AA case tests the scope for relying upon this groundbreaking development. In this article we shall set...
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Chris Morgan, Head of KPMG's EU Tax Group, and Jonathan Bridges, of KPMG's EU Tax Group, comment on the A-G's Opinion delivered in Oy AA Case C-231/05
Chris Morgan Head of KPMG's EU Tax Group and Jonathan Bridges of KPMG's EU Tax Group comment on the A-G's Opinion delivered in Oy AA Case C-231/05
On 12 September 2006 Advocate-General (A-G) Kokott delivered her Opinion in the Oy AA case. The case considers whether a profitable Finnish company should be entitled to relieve its profits against overseas group company losses. With the European Court of Justice (ECJ) having recently established a cross-border profit-loss offset principle in M&S Case C-446-03 the Oy AA case tests the scope for relying upon this groundbreaking development. In this article we shall set...
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