Relief for overseas losses for Marks & Spencer plc
The Tax Tribunal has now allowed, in principle, Marks and Spencer’s claim for group relief in respect of the losses of its Belgian and German subsidiaries. The tribunal held that in March 2007, when the taxpayer made valid claims, the losses could not have been taken into account in Belgium or Germany. (Marks & Spencer plc v Revenue & Customs Comrs TC00005).
This is not exactly a breakthrough but does clarify the position.
Cathy Corns is a tax adviser and a partner at Mercer & Hole. The views given in this blog are personal to the author.
Date: 25th September, 2009
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