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CROSS-BORDER-LOSS-RELIEF


Two recent CJEU decisions restrict the scope of the Marks & Spencer decision on cross-border loss relief.
Ashley Greenbank (Macfarlanes) picks out some highlights in a year of political and economic turmoil.
 
The government is exploring taxing certain non-resident companies under corporation tax. Philip Spencer and Robin Hutton (BDO) consider the possible implications.
 
From 1 April 2017, there will be a substantial change to how corporation tax losses can be carried forward. Ben Jones and Dean Andrews (Eversheds Sutherland) examine the detail.
 
Sarah Lane and Jack Lewis (FTI Consulting) look at the background and the effect of the proposals using worked hypothetical examples.
 

HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).

Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.

The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.

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