Alternative Tax Strategies

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...