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UK Supreme Court dismisses all appeals in Marks & Spencer tax dispute

3 Mar 2014

First published in International Tax Review, 21 February 2014

The Supreme Court judgement clearly defined the rules and method of calculation for UK claims for cross-border loss relief in Europe.

The case revolves around a claim by Marks & Spencer (M&S), the retailer to offset losses incurred by two of its European subsidiaries, Marks and Spencer Deutschland (MSD) and Marks and Spencer Belgium (MSB), against its UK corporation tax bill.

"It wasn't an out and out victory for M&S as the court rules in favour of HMRC in respect of certain claims that related to accounting periods pre-self-assessment where under the 'pay and file' regulations the group was effectively out of time for making a valid claim" said Jonathan Hornby, Taxand UK.

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