HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).
Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.
The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.
