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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...

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