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The long-running saga of Marks & Spencer and cross-border group relief
KEY POINTS
- Marks & Spencer wished to set tax losses in its overseas subsidiaries against its UK taxable profits.
- The UK’s refusal to allow the claim was deemed by the European Court of Justice to be unduly restrictive.
- The European Commission took issue with the UK legislation implementing the decision.
- The Advocate General’s opinion European Commission v UK in effect reverses the ECJ’s original decision.
- Nine years is a long time to wait for almost anything but when it comes to tax law – and especially EU tax law – it is just the blink of an eye. So it might seem anyway when we realise that a fundamental tax principle which was decided at the highest level nearly nine years ago might not be final after all.
Such...
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