Market leading insight for tax experts
View online issue

HMRC v Marks & Spencer plc

The decision in HMRC v Marks & Spencer plc (No. 3) (and cross-appeal) (Supreme Court – 22 May) is the latest instalment in a long-running saga. The company (M) had claimed loss relief in respect of losses incurred by subsidiary companies in Belgium France and Germany. The First-Tier Tribunal (FTT) allowed M’s appeals in principle with regard to the German and Belgian subsidiaries holding that at 20 March 2007 when M had made valid claims to group relief there were no possibilities of the losses being taken into account in Germany or Belgium. HMRC appealed to the Upper Tribunal which upheld the FTT decision in favour of M for the periods ending March 2000 to March 2002 and upheld the FTT’s decision in favour of M with regard to the quantification of the losses. (However the Upper Tribunal found in favour of HMRC...

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top