Chris Morgan provides a review of recent international tax developments, including the Court of Appeal decision in Marks and Spencer.
What’s hotSix years after the landmark decision by the European Court of Justice (ECJ) in Marks & Spencer v Halsey (Case C-446/03) (M&S) allowing cross-border group relief the finer details of this case are still being debated in the UK courts.
On 14 October 2011 the Court of Appeal published its decision in the latest instalment of this long running case.
Most readers will be familiar with the background so I will only mention it briefly.
It was argued that in not allowing EU subsidiaries to surrender losses to UK group companies the UK group relief...
