Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases gives us the latest tax case news
Marks & Spencer plc v HMRC (TC00005 — 1 May)
A UK company (M) established subsidiary companies in Belgium France and Germany. These subsidiaries made losses. M claimed group relief on the basis that it should be entitled to set the losses which these companies made against its UK profits. HMRC rejected the claim and the case was referred to the ECJ which held that it was contrary to Articles 43 and 48 of the EC Treaty to prevent a resident parent company from deducting from its taxable profits losses incurred in another Member State by a subsidiary established...
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Alan Dolton Editor of Tolley's Tax Cases and Tolley's VAT Cases gives us the latest tax case news
Marks & Spencer plc v HMRC (TC00005 — 1 May)
A UK company (M) established subsidiary companies in Belgium France and Germany. These subsidiaries made losses. M claimed group relief on the basis that it should be entitled to set the losses which these companies made against its UK profits. HMRC rejected the claim and the case was referred to the ECJ which held that it was contrary to Articles 43 and 48 of the EC Treaty to prevent a resident parent company from deducting from its taxable profits losses incurred in another Member State by a subsidiary established...
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:
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