Christian Ehlermann Tax Partner Munich and Katja Nakhai Senior Tax Manager Deloitte consider the ECJ's decision on cross-border loss relief in Marks & Spencer and the impact the decision will have in Germany
As has been widely reported the ECJ has decided in its much anticipated Marks & Spencer (M&S) judgment that cross-border loss relief in the UK is possible under the restriction that the UK parent's EU subsidiary has exhausted all possibilities in its state of residence for offsetting the losses. In particular the loss claimant would have to prove that the non-resident subsidiary has exhausted all possibilities available in its state of residence of having the losses taken into account:
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Christian Ehlermann Tax Partner Munich and Katja Nakhai Senior Tax Manager Deloitte consider the ECJ's decision on cross-border loss relief in Marks & Spencer and the impact the decision will have in Germany
As has been widely reported the ECJ has decided in its much anticipated Marks & Spencer (M&S) judgment that cross-border loss relief in the UK is possible under the restriction that the UK parent's EU subsidiary has exhausted all possibilities in its state of residence for offsetting the losses. In particular the loss claimant would have to prove that the non-resident subsidiary has exhausted all possibilities available in its state of residence of having the losses taken into account:
● for...
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.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")