The decision in HMRC v Marks & Spencer plc(Upper Tribunal – 21 June) is the latest instalment in a long-running saga. A UK company (M) had 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.
The Revenue rejected the claim and M appealed contending that the relevant provisions of the UK legislation which prevented an EU-resident subsidiary trading outside the UK...
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The decision in HMRC v Marks & Spencer plc(Upper Tribunal – 21 June) is the latest instalment in a long-running saga. A UK company (M) had 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.
The Revenue rejected the claim and M appealed contending that the relevant provisions of the UK legislation which prevented an EU-resident subsidiary trading outside the UK...
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:
