Treasury plans ECJ changes

The government will bring forward changes to UK tax law in due course to deal
with the M&S judgment, the Treasury said today.

Responding to the ECJ’s verdict on group relief, the Treasury said in a
statement: ‘We believe that the judgement means that the UK’s existing system of
Group Relief can be preserved, broadly as it is now.’

It adds: ‘The court’s judgement emphasises that the UK’s rules are in
principle compatible with EU law, but we accept that in a very small number of
very limited circumstances the UK may have to allow relief for losses of the
foreign subsidiaries of UK companies, where there is no possibility of those
losses being relieved in the EU country the foreign subsidiary is based in.

‘The Government will bring forward detailed proposals in due course, and our
intention is to consult with business on the detail of how the group relief
should be amended to bring it fully in line with EU law.’

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