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).
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.
Chris Morgan reviews recent international tax developments, including updates from Canada, as well as the OECD’s BEPS project and common reporting standard, CJEU judgments on German exit taxes and the Hungarian ‘crisis tax’, and the M&S Supreme Court decision
After 11 years of litigation, the Supreme Court has held that a claimant can make successive claims for cross-border group relief as long as they are not time barred. Simon Whitehead and Rachel Garwood review the decision and examine the implications
Nick Skerrett examines the impact of the Leeds City Council case
The G8 summit at Lough Erne leads the month's summary from Chris Morgan