Matthew Rose British Telecommunications plc discusses alternative tax strategies for UK-owned loss-making group companies
If a European subsidiary company is loss-making then under current UK tax legislation relief cannot be obtained for overseas tax losses against UK taxable profits. This therefore would push up the group's consolidated tax charge reduce earnings per share and does not give cash flow savings. Whilst UK tax relief for European losses of group companies is currently a hot topic this article considers alternative ways to obtain relief whilst awaiting the European Court of Justice (ECJ) hearing of the Marks & Spencer case and any repercussions arising from the subsequent decision.
This article therefore assumes that the ECJ will find in the Inland Revenue's favour and/or that other anti-avoidance measures are...
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Matthew Rose British Telecommunications plc discusses alternative tax strategies for UK-owned loss-making group companies
If a European subsidiary company is loss-making then under current UK tax legislation relief cannot be obtained for overseas tax losses against UK taxable profits. This therefore would push up the group's consolidated tax charge reduce earnings per share and does not give cash flow savings. Whilst UK tax relief for European losses of group companies is currently a hot topic this article considers alternative ways to obtain relief whilst awaiting the European Court of Justice (ECJ) hearing of the Marks & Spencer case and any repercussions arising from the subsequent decision.
This article therefore assumes that the ECJ will find in the Inland Revenue's favour and/or that other anti-avoidance measures are...
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:
