Katherine Brown thinks that HM Treasury is starting to respond rationally to CJEU ruling
Draft Finance Bill measures suggest that HM Treasury is starting to respond rationally to the challenges of complying with EU legislation while retaining anti-avoidance rules.
The draft Finance Bill 2013 includes several efforts to bring UK tax legislation into line with EU law following recent challenges in the European Court of Justice (CJEU). The key measures are:
Changes to group relief rules for UK permanent establishments: Currently a non-resident company can surrender losses realised by its UK permanent establishment (PE) to UK resident members of its worldwide group but not if there is a possibility of relief for the loss in another jurisdiction. From 1 April 2013 UK PE losses will only be denied...
