The Resource Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries

Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries

Label
Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries
Title
Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries
Creator
Subject
Language
eng
Summary
The First-Tier Tribunal in the United Kingdom has found in favour of Marks and Spencer. The result means that the United Kingdom will have to give relief for the final losses of the Belgian and German subsidiaries of Marks and Spencer. The ruling of the Tribunal, which may be appealed, finally gives effect to the December 2005 judgment of the European Court of Justice (ECJ) in Marks and Spencer v David Halsey. The Tribunal emphasised that paragraph 55 of the ECJ's judgment should be given some effect rather than no effect. Consequently, the Tribunal modified parts of the United Kingdom's group relief regime to ensure that Marks and Spencer could obtain the remedy suggested by the ECJ in its judgment for the final and unrelieved losses of their Belgian and German subsidiaries
Citation source
In: Highlights & Insights on European taxation. - Deventer. - Vol. 2 (2009), no. 7/8 ; p. 16-42
http://library.link/vocab/creatorName
O'Shea, T
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • case law
  • Marks & Spencer case
  • cross-border loss relief
  • group treatment
  • non-resident company
Label
Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries
Instantiates
Publication
Label
Marks and Spencer Plc. Group relief for losses of non-resident subsidiaries
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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