This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Lloyds Asset Leasing and Royal Bank of Canada, as well as HMRC’s plans to update guidance on the salaried member rules.
Lloyds Asset Leasing: purpose test
In Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) the First-tier Tribunal (FTT) agreed with HMRC that cross-border group relief was excluded by the anti-avoidance provision designed to deny group relief where arrangements have been made creating a cross-border loss or creating the conditions where a cross-border loss can be claimed. The cross-border group relief legislation was the UK’s response to the Marks & Spencer case in which the ECJ as it then was held that under EU law the UK was required to permit cross-border group relief in certain (very) limited circumstances. Unsurprisingly after Brexit the UK was quick to repeal...
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This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Lloyds Asset Leasing and Royal Bank of Canada, as well as HMRC’s plans to update guidance on the salaried member rules.
Lloyds Asset Leasing: purpose test
In Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) the First-tier Tribunal (FTT) agreed with HMRC that cross-border group relief was excluded by the anti-avoidance provision designed to deny group relief where arrangements have been made creating a cross-border loss or creating the conditions where a cross-border loss can be claimed. The cross-border group relief legislation was the UK’s response to the Marks & Spencer case in which the ECJ as it then was held that under EU law the UK was required to permit cross-border group relief in certain (very) limited circumstances. Unsurprisingly after Brexit the UK was quick to repeal...
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:
