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Pan-EU Loss Relief Post

 
Chris Morgan Head of KPMG's EU Tax Group and Jonathan Bridges Senior Manager in KPMG's EU Tax Group take a look at what the ECJ's decision in M&S could mean for taxpayers across the EU
 
Readers will by now be fully aware of the ECJ decision in Marks & Spencer plc v Halsey delivered on 13 December 2005.
 
One could ask 'Will the judgment really make any difference across the EU?'. Unsurprisingly a number of Member States have confidently declared it is business as usual and that the ECJ's decision will have little or no impact on their existing loss relief rules. For example The Netherlands' government wasted little time in announcing that proposed changes to its rules to allow cross-border fiscal unities were no...

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