Relief for branch losses?
A preliminary decision by the Advocate General has indicated that the losses of a UK resident permanent establishment of a Dutch company should be allowable against profits of a UK resident group company. This is a potentially important decision as it could open up the opportunity for additional claims for relief against UK tax.
It should be stressed that the opinion is not legally binding, any such outcome can only come from a decision by the European Court of Justice. Historically, however the court has followed the Advocate General’s opinion.
Bearing in mind the time limits on claims for group relief you may wish to consider making a provisional claim if the ruling would potentially affect you.
Date: 16th July, 2012
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