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Relief for M&S

Roopa Aitken and Natalie Carroll of Grant Thornton UK LLP consider the latest instalment in the long-running saga on EU group relief
On 1 May 2009 the Tax First-tier Tribunal (previously known as the Special Commissioners) published its decision in the Marks & Spencer TC 00005 group relief case. Tribunal Judges John Avery Jones CBE and Malcolm Gammie CBE QC had to consider this case again — more than six years after they originally gave their decision in favour of HMRC.
Background to the Case
Many readers will be very familiar with the facts of the case since it has obtained much publicity over the years and so here is just a brief summary as a...

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