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Philips Electronics and UK group relief

Roopa Aitken and Hannah Tilson consider the implications of the Advocate General's opinion in the Philips case.

On 19 April 2012 Advocate General Kokott (AG) released her opinion in the Philips Electronics UK Ltd case (C-18/11) currently before the Court of Justice of the European Union (CJEU). The case concerns a UK company’s claims to offset losses of a UK branch of a Dutch company against its profits. The claims were made on the basis that the UK group and consortium relief rules are contrary to European law specifically the freedom of establishment enshrined in Article 43EC (now Article 49 Treaty on...

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