David Simpson considers whether cross-boarder group relief claims can be made under Marks & Spencer principles in respect of losses stranded by operation of law as distinct from terminal loss claims
Judy Harrison considers the impact of the two appeals relating to M&S's claims to group relief for the losses of its non-UK subsidiaries
Robert Langston considers the tax issues which arise when an overseas company undertakes activities in the UK
HMRC has issued updated thin capitalisation guidance. John Neighbour and Daniel Head explain the new challenges for taxpayers that have borrowed from connected parties
Your guide to the live consultations
Rupert Shiers and Kit Dickson simplify the complex decision in Test Claimants in the FII GLO, and explain 'what next' for EU claims and High Court claims in particular
Richard Doran and Robert Waterson consider ongoing remedy and jurisdiction issues following recent decisions in the VIC and FII GLOs
Simon Whitehead, partner, Dorsey & Whitney, London, reviews an uncertain state of affairs
Mark Joscelyne and Hugo Webb of Olswang LLP discuss the worldwide debt cap in FA 2009, Sch 15